Setting the Global AI Standard: Our Response to the American AI Exports Program

Artificial intelligence (AI) is rapidly becoming the engine of global economic competitiveness, and the United States has only a narrow window to secure its leadership. The nations that succeed will not simply set the rules, they will export the technologies, infrastructure, and capabilities that power the world’s AI transformation. By expanding the reach of U.S. AI technologies abroad, the U.S. can anchor global supply chains, strengthen strategic alliances, and ensure that the next generation of AI is built on American innovation and values.

To help advance this critical national priority, Scale AI today submitted our response to the U.S. Department of Commerce’s International Trade Administration’s Request for Information (RFI) on the proposed “American AI Exports Program.” We strongly support this initiative as part of the Trump Administration’s focused effort to accelerate U.S. technology exports and reinforce American leadership in the global AI economy.

Our Perspective and Experience

Established in 2016, Scale’s mission is to develop reliable AI systems for the worldʼs most important decisions. We provide high-quality data and full-stack technologies that power the worldʼs leading models, and enable enterprises and governments to build, deploy, and oversee applications that deliver real impact.

Our diverse and far-reaching experience places us at the center of nearly every major breakthrough in AI over the last ten years and gives us a deep understanding of what it takes to build and deploy high-quality systems at scale worldwide.

A Critical Moment for U.S. AI Leadership

In the coming months, the global standard for AI will be set—and the world will choose between a future shaped by the United States or one defined by the Chinese Communist Party. We have seen this dynamic before. In the global 5G race, early Chinese dominance created enduring strategic vulnerabilities for the United States and our allies. We cannot afford to repeat that mistake.

Winning this race demands a whole-of-government strategy that moves at the speed of innovation. Exporting the American AI tech stack is not optional—it is a strategic imperative. By ensuring that U.S. technologies, not authoritarian alternatives, become the backbone of global AI infrastructure, we secure both our economic leadership and our national security.

Defining the AI Tech Stack

Our comments emphasize the need to clearly define the AI technology stack to ensure successful export and adoption worldwide. The AI tech stack comprises of four key components, and each is required for effective AI deployment:

• Compute: Advanced chips and adequate power remain essential for state-of-the-art model development. Compute is critical but insufficient on its own.
• Data: Data is a nation’s most important sovereign asset. Effective AI depends on high-quality, contextually relevant data, and countries must begin with their own sovereign datasets.
• Model: Rapid advancements in open- and closed-source models provide many viable options. A model-agnostic approach is often optimal, since performance is task-dependent.
• Applications: True AI capability depends on integrating applications that translate model performance into real operational impact.

While investment and policy is currently skewed towards constructing data centers to secure compute capability, all four components – and the relationships among them – must be considered to deliver meaningful AI outcomes. U.S. leadership requires more than producing the strongest AI models. The country that defines the global AI paradigm AI must lead across the full tech stack.

Key Ways to Successfully Export the AI Stack

We also put forth several recommendations that address key themes to inform the “American AI Exports Program,” most notably:

• Flexibility in consortia formation: Rigid structures could hinder U.S. competitiveness. Each project and country requires customized solutions.
• Clearer differentiation between models and applications: These are distinct layers requiring different export considerations and governance frameworks.
• Structured participation by foreign partners: Many deployments require integration with sovereign data or local institutions. Allowing participation where necessary strengthens America’s diplomatic objectives while keeping the U.S. tech stack central.
• Leadership in standards: Global AI leadership must begin with leadership in technical standards, echoing lessons learned from 5G.

Looking Ahead

Scale welcomed the opportunity to provide our input on the American AI Exports Program to help secure U.S. leadership in global AI. We look forward to continuing to work with the Administration, Department of Commerce and other federal agencies to advance a secure, competitive, and innovation-driven American AI technology stack abroad. To read the full response, click here.