Why Commerce’s Anthropic export letter may be legally flawed

The critique argues that Commerce’s letter to Anthropic stretches export-control rules because access to a hosted model may not constitute an export of an item

We've got the full text of the Lutnick letter. Anthropic may well want to resolve this out of court, but the letter is legally deeply flawed: 1. There's no "export" here to restrict. The letter relies on EAR § 744.22, which allows BIS to r