Policy Blog Templates (33)

SIIA Submits Comments on NIST 800-1 Draft Guidance on Managing Misuse Risk for Dual Use Foundation Models

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The Software & Information Industry Association (SIIA) submitted feedback on the initial draft of NIST 800-1, “Managing Misuse Risk for Dual-Use Foundation Models.” SIIA recommends several changes to improve the utility and adoption of these practices.

Key Points from SIIA’s Feedback:

    1. Calibrate Recommended Practices: SIIA emphasizes the need for AISI to recognize the current limitations in measuring and mapping misuse risks. They suggest that AISI should provide technical guidance where available and label practices as “aspirational” where such guidance is lacking.
    2. Account for Model Variations: The 800-1 draft presumes uniformity among dual-use models, which SIIA believes is misleading. They recommend tailoring guidelines to account for different characteristics of foundation models, such as the degree of openness, to better foresee and manage misuse risks.
    3. Engage the Entire AI Value Chain: SIIA argues that managing misuse risk is not solely the responsibility of model developers. They recommend AISI expand its guidance to include all stakeholders in the AI value chain, from development to deployment.
    4. Consider Downstream Implications: SIIA urges AISI to be mindful of the potential regulatory impact of its recommendations. They caution against overly broad or unrealistic expectations that could stifle AI innovation or expose companies to undue legal risks.
    5. Recommendations for Improvement:
      • Engage with the NIST AISI Consortium before finalizing the 800-1 draft.
      • Incorporate language reflecting scientific and technical limitations.
      • Consolidate research on identifying and managing misuse risks.
      • Promote harmonization of AI safety standards across jurisdictions to reduce compliance burdens.shorter
Full Letter Here
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SIIA’s Opposition to Chicago Ordinance 2-68-050: Data Residency Requirements

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The Software & Information Industry Association (SIIA) is urging the City Council of Chicago to reject Ordinance 2-68-050, which mandates data residency requirements for City data. SIIA represents approximately 375 companies involved in various sectors of digital content and information services. In their letter, SIIA argues that the ordinance, which would localize data storage within the city or state, would have negative unintended consequences. These include increased cybersecurity risks, as centralizing data locally would make it a more visible target for malicious actors. Additionally, the ordinance could impede the use of advanced cloud computing solutions that offer greater efficiency and security.

Moreover, SIIA highlights the financial impact of the ordinance. The proposed data localization would drive up costs by requiring the City to build and maintain local data storage infrastructure, eliminating the cost-saving benefits of current cloud-based, large-scale solutions. These increased storage costs would strain the City’s budget and reduce overall revenue. SIIA’s letter emphasizes that this policy would ultimately undermine its intended goals, and they welcome further discussion with the Committee on this issue.

Full Letter Here
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SIIA Statement on the DOJ’s Lawsuit Targeting Google’s Online Advertising Services

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The following statement from the Software and Information Industry Association (SIIA) regarding the Department of Justice (DOJ) and state attorneys general’s antitrust lawsuit against Google’s ad tech that begins today can be attributed to Paul Lekas, Senior Vice President, Global Public Policy.

SIIA remains deeply concerned by the decision to bring this litigation. The ad tech space is a dynamic and highly competitive one in which low barriers to entry have resulted in continuing innovation. The action taken by the Department of Justice and state attorneys general would benefit Google’s competitors in the ad tech space, not the small and medium-sized businesses that choose to use Google’s innovative ad tech offerings because they make it easier to access dozens of non-Google platforms as well as Google services.

In such an environment, it’s a bedrock principle that private businesses may decide whether to do business with competitors, and on what terms. Google is already doing more than the law requires by providing its competitors with access to its products, thereby allowing customers to fashion the solution that works best for them. Given the robustly competitive online advertising environment, the case is ill-advised and risks setting a dangerous precedent that would erode competition and innovation.

Policy Blog Templates (78)

SIIA Joins Over 70 Organizations in Opposing NextNav’s FCC Petition

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SIIA joins over 70 organizations in opposing NextNav’s petition to the Federal Communications Commission (FCC) regarding the reorganization of the 902-928 MHz band. The coalition argues that NextNav’s proposal to create a 5G terrestrial-based Positioning, Navigation, and Timing (PNT) network could severely disrupt the operations of Part 15 unlicensed devices, which are critical across various industries. These devices, which rely on this frequency band, play a key role in sectors such as municipal infrastructure, utilities, railroads, and agriculture. The coalition stresses that current FCC rules requiring coexistence testing protect these devices from harmful interference, and eliminating these protections could cause significant disruption to both public and commercial operations.

The letter highlights how Part 15 devices drive productivity and safety in areas like smart home systems, tolling, retail operations, and agriculture. The coalition disputes NextNav’s claim that the band is underutilized and expresses concern over the lack of technical analysis provided in the petition. They urge the FCC to maintain existing rules that safeguard Part 15 devices, allowing industries to continue benefiting from the band’s reliable communication capabilities. Without these protections, innovations and essential services across multiple sectors could face widespread disruptions.

Full Letter Here
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Defending Democracy, Not Silencing It: Why SIIA and Partners Oppose AB 2655

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The Software & Information Industry Association (SIIA), along with the California Chamber of Commerce (CalChamber), NetChoice, TechNet, and the Computer & Communications Industry Association (CCIA), urged California Governor Gavin Newsom to veto AB 2655. These organizations acknowledge the importance of addressing online election disinformation but argue that AB 2655 would not effectively achieve this goal. They contend that the bill wrongly assumes that online platforms can accurately determine manipulated content and could lead to over-blocking of political speech, infringing on First Amendment rights.

The coalition further argues that AB 2655 imposes impractical requirements on large platforms and risks excluding smaller ones where misinformation may also appear. They express concerns about the bill’s enforcement provisions, which they believe could cause platforms to remove more content than necessary, including truthful election information, due to the stringent timeline for compliance and fear of liability. Instead, they advocate for AB 2355, which focuses on holding accountable those creating misleading content rather than the platforms hosting it. The letter concludes by emphasizing the need for a balanced approach that avoids chilling online political speech.

"We are all for defending democracy from deepfake deception. This is a problem in need of a solution, but there is no easy fix. The legislation would demand that platforms make complicated value judgments about political content without clear guidance and apply 'state-of-the-art techniques' that do not exist. This bill will not stop bad actors, and the threat of legal liability will lead platforms to remove legitimate political speech. The use of disinformation to further partisan political goals is an important issue that should be addressed constructively by government, industry, and civil society."
Paul Lekas
Senior Vice President, Global Public Policy
Full Letter Here