Cyberlaw Clinic, Researchers File Comment re: OMB AI Draft Memo

On Friday, March 13th, the Cyberlaw Clinic and a team of researchers based at the Berkman Klein Center for Internet & Society filed an administrative comment addressing the United States Office of Management and Budget’s “Draft Memorandum to the Heads of Executive Departments and Agencies, ‘Guidance for Regulation of Artificial Intelligence Applications.'” The Draft Memorandum aims to provide guidance to inform federal agencies’ “development of regulatory and non-regulatory approaches regarding technologies and industrial sectors that are empowered or enabled by artificial intelligence (AI)” and encourage agencies to “consider ways to reduce barriers to the development and adoption of AI technologies.” Researchers who joined the comment include Amar Ashar, Ryan Budish, and Adam Nagy of the Berkman Klein Center  for Internet & Society and the Clinic’s own Chris Bavitz, Jessica Fjeld, and Mason Kortz.

The comment provides “economic and social context to demonstrate that regulation and innovation are not mutually exclusive.” It evaluates the Draft Memorandum’s promotion of cost-benefit analysis, and it provides detailed responses to the principles itemized in the Draft Memorandum.

Our Cyberlaw Clinic students did an amazing job putting this together — João Marinotti (HLS JD ’20) worked for several weeks to help frame and tee up the arguments with the researcher signatories, and João worked with Jonathan Iwry (HLS JD ’20) and the research team to finalize the comment in the run-up to Friday’s filing.  This was especially remarkable last week, as the comment came together in the midst of Harvard University’s move to remote learning and teaching. The new University policies affect the research team at the Berkman Klein Center, the staff of the Cyberlaw Clinic, and — most notably — our students, who have really stepped up to the challenge as we radically change our approach to Clinic work for the second half of the semester. Thanks to João and Jonathan for their great work, especially under these complicated circumstances.

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