October 17, 2022
Filed electronically via www.regulations.gov, Docket No. ITA-2022-0007
Barton Meroney
Executive Director
Office of Manufacturing Industries International Trade Administration 1401 Constitution Avenue, NW Washington, DC 20230
Re: Request for Comments on Artificial Intelligence Export Competitiveness, Docket No. ITA-2022-0007, 87 Fed. Reg. 50288, pp. 50288-89 (August 16, 2022)
Dear Director Meroney:
The Entertainment Software Association1 (“ESA”) welcomes the opportunity to respond to the International Trade Administration’s (“ITA”) request for comments on stakeholder concerns regarding international policies, regulations and other measures which may impact U.S. exports of artificial intelligence (“AI”) technology. Because AI and machine learning technology present revolutionary opportunities in both game development and game operations, we use this opportunity to call attention to industry priorities and concerns in technology policy generally and particularly, in the context of international trade and global policymaking. ESA’s comments in response to the Federal Register notice (“FRN”) focus on aspects of intellectual property, digital trade and market access that are important to the economic competitiveness of video game companies. Our submission also counsels the U.S. government to stay the course on supporting fair digital trade principles, strong intellectual property laws and an evidence-based approach to regulation to maintain the rapid pace of innovation in the AI space.
