The Cyberlaw Clinic worked with Harvard computer science professors Finale Doshi-Velez and Elena L. Glassman to prepare and submit an administrative comment to the National Institute of Standards and Technology (“NIST”). NIST requested information to help it carry out its responsibilities under President Biden’s Executive order on Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, issued on October 30, 2023. Doshi-Velez and Glassman urge NIST to support “the creation of an open benchmarking platform that would empower marginalized communities to define criteria for measuring how well [large language models] represent their language and culture.” They further suggest that NIST acknowledge that “some amount validation must be done at task time (i.e., at the moment a user engages with AI to perform a task), rather than—or in addition to—in advance of deployment.” HLS winter term advanced clinical student Carli Sley worked on the comment, along with the Clinic’s Managing Director, Christopher T. Bavitz.