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Additional details are present in the unpublished rule (document 2019-27649 [1][2]). -- cut -- Geospatial imagery “software” “specially designed” for training
by withinrafael 7y ago
Additional details are present in the unpublished rule (document 2019-27649 [1][2]).
-- cut --
Geospatial imagery “software” “specially designed” for training a Deep Convolutional Neural Network to automate the analysis of geospatial imagery and point clouds, and having all of the following:
1. Provides a graphical user interface that enables the user to identify objects (e.g., vehicles, houses, etc.) from within geospatial imagery and point clouds in order to extract positive and negative samples of an object of interest;
2. Reduces pixel variation by performing scale, color, and rotational normalization on the positive samples;
3. Trains a Deep Convolutional Neural Network to detect the object of interest from the positive and negative samples; and
4. Identifies objects in geospatial imagery using the trained Deep Convolutional Neural Network by matching the rotational pattern from the positive samples with the rotational pattern of objects in the geospatial imagery.
Technical Note: A point cloud is a collection of data points defined by a given coordinate system. A point cloud is also known as a digital surface model.
-- cut --
[1] https://www.federalregister.gov/documents/2020/01/06/2019-27649/addition-of-software-specially-designed-to-automate-the-analysis-of-geospatial-imagery-to-the-export https://www.federalregister.gov/documents/2020/01/06/2019-27...
[2] https://s3.amazonaws.com/public-inspection.federalregister.gov/2019-27649.pdf https://s3.amazonaws.com/public-inspection.federalregister.g...
- lopmotr 7y agoIt seems strangely ambiguous: "(geospatial imagery) and (point clouds)" or "geospatial (imagery and point clouds)"? Point 4 requires the use of geospatial imagery, so any point-cloud-only product would be exempt, it seems? The document doesn't define "geospatial imagery", but that could surely include hobby and commercial drone footage of the ground. Perhaps even ordinary photography from security cameras that have user-define object identification features? That would make it really quite broad. But all we need to do is not normalize color, and then everything's exempt!
- Frost1x 7y agoWas doing similar work on a project using sonar imaging for the bottom of water bodies to much of what they're excluding. Not sure how concerned they'd be with identify freshwater creatures and riverbed structures...
- jahewson 7y agoYou’re forgetting that how the word “and” works in English is often not the same as logical AND, e.g. in “give me a list of people who live in New York and Los Angeles” the “and” means OR.
- lopmotr 7y agoGood point. Though I think "and" in those other cases really means something like "additionally" or "plus" rather than OR. You sentence could be written "... list of people who live in NY and people who live in LA.". But it's still confusing here. If they mean it applies to both imagery software and point cloud software, then point cloud software would be excluded in point 2 because it doesn't have pixels or color (if lidar/etc). So it must be software that uses both. That makes more sense if it's aimed at a specific existing product.
- incompatible 7y agoThe "graphical user interface" bit is weird. I suppose you are fine if the software is driven entirely by keyboard shortcuts.
- extropy 7y agoIMO that's an indication that this was made for a specific piece of software and trying to limit the collateral damage.
- incompatible 7y agoYes, it seems very specific.
- atmosx 7y agoSame here. They are framing a specific software, possibly a very specific business deal from happening.
- peter303 7y agoMaxar
- floatingatoll 7y agoNot so weird. Palantir put a GUI on Hadoop/whatever and that was enough to sell it to every government for citizen inspection. It’s the GUI that gets the contracts, not the technology alone.
- oefrha 7y agoIf a government 1) wants to acquire a geospatial imagery recognition program; 2) does not have the tech themselves; 3) can import the underlying tech without interface; I highly doubt a restriction on GUI export will stop them.
- Aperocky 7y agoBut in the mind of the geniuses that make up the US Congress, it does. How will anyone operate a computer without GUI? That’s impossible! /s
- oefrha 7y agoSo image recognition APIs like ones provided by AWS and GCP should be affected by this due to #2 and #3, no? Or the “provides a graphical user interface” part applies to all points? Edit: I overlooked “have all of the following”.
- incompatible 7y agoWell, it says "having all of the following", so I think an API is fine.
- oefrha 7y agoOh, sorry, didn’t see that. Seems kinda pointless then.
- tgsovlerkhgsel 7y agoThe main restriction is "“specially designed” for training a Deep Convolutional Neural Network to automate the analysis of geospatial imagery and point clouds".
- oefrha 7y agoAnd having a GUI. It appears you can simply export a binary framework (with or without source) and let the buyer build an interface on top of it. Building an interface is not terribly advanced work and can be done by fresh bootcamp grads even...
- IanCal 7y agoStrangely given that it has to meet all requirements, doesn't that mean multiple people could release two or three different projects that work together? Although saying "well technically" as you get dragged off for waterboarding may not make you feel better.
- sytelus 7y agoGosh! There are like thousand github repos that do these stuff. This could become a tool to prosecute a lot of unwanted people like DeCSS.
- spectramax 7y agoCould you please provide a few github links?
- sytelus 7y agoObject detection in aerial images is a rather booming field with 100s of papers published on the topic and contests going on in top conferences. I wouldn't be surprised if OSM is also doing some of this. In about 5 minutes I could find these: https://github.com/search?q=geospatial+deep+learning https://github.com/search?q=geospatial+deep+learning https://github.com/search?q=satellite+images+deep+learning https://github.com/search?q=satellite+images+deep+learning https://github.com/search?q=aerial++deep+learning https://github.com/search?q=aerial++deep+learning https://github.com/search?q=aerial+object+detection https://github.com/search?q=aerial+object+detection
- jefftk 7y agoIt looks like these don't meet (1) because they don't have "a graphical user interface that enables the user to identify objects"
- kortilla 7y agoWith a GUI and everything? I find it hard to believe there are a thousand projects doing that.
- ehnto 7y agoLots of interesting precedent to come out of it as well. By putting code on Github, an American website, as a developer are you actually exporting it? Or are the people cloning the repo reaching into America and extracting it? If it is considered exporting, is github the exporter, or is the developer. Just like a company might produce a metal widget but another company procures and exports it, the original company that made the widget isn't the exporter.
- salty_biscuits 7y agoSo is Esri worried?
- vajrabum 7y agoThat would have been my guess at who this is aimed at too. Lots of applications outside the military and spook shops but that's always been the primary customer.
- Aperocky 7y agoWith a GUI lol, phew. Yeah almost nothing will fall under that. Build your own GUI (if you ever need one).
- ynniv 7y agoThis overly specific intersection of requirements is how you target a single product in legislation.
- im3w1l 7y agoAh, I was scratching my head reading through it thinking about how unlikely it must be for something to have all of those properties. But if they were tailor made for a single product that makes sense.
- marcosdumay 7y agoLooks to me like it fits all those "model training on a GUI" packages people are selling today. That will place the US in a large economical disadvantage for those.
- TuringNYC 7y agoCan anyone comment on who the specific vendor or what specific product might be? The AND-criteria makes this restriction pretty narrow, and the GUI requirement alone rules out practically everything I can think of.
- tbihl 7y agoI saw a great example of this when I was looking at VA gun laws today. They have an exception structured as follows: Virginia law exempts from these requirements any firearms shows held in any town with a population of not less than 1,995 and not more than 2,010, according to the 1990 United States census [1] [1] https://lawcenter.giffords.org/gun-shows-in-virginia/ https://lawcenter.giffords.org/gun-shows-in-virginia/
- bluepickles 7y ago"The provisions of this section shall not apply to firearms shows held in any town with a population of not less than 1,995 and not more than 2,010, according to the 1990 United States census." https://law.lis.virginia.gov/vacode/title54.1/chapter42/section54.1-4201.1/ https://law.lis.virginia.gov/vacode/title54.1/chapter42/sect...
- 7y ago
- ArtWomb 7y agoThe export ban is on the software? Not the algorithm itself? And would it be broad enough that all AI and QI frameworks like PyTorch, Tensorflow and Qiskit would fall under its purview. These restrictions seem to flow from a mental model that still views software as a product purchased in a shrink-wrapped box. Rather than the services based model currently extant.
- grepfru_it 7y agoThat is the point, to delay the adversary from gaining access to completed technology. An example is foreign adversaries purchasing PS3s with Linux to quickly access cheap computing power. Whether frameworks are at risk is limited to the wording of the ban and then the final determination comes from a judge hearing the case. The chilling effects are real and its possible framework development may very well be hampered due to the unknowns you have pointed out in your post
- 616c 7y agoThe PS3 thing is a contrived example or this really was happening?
- karmelapple 7y agoReal! Check out number 1 here: https://www.visualcompliance.com/blog/?p=185 https://www.visualcompliance.com/blog/?p=185
- 616c 7y agoCool, thanks. I will check it out!
- nl 7y agoAnd would it be broad enough that all AI and QI frameworks like PyTorch, Tensorflow and Qiskit would fall under its purview. No. They look like they are targeting a specific piece of commercial software.
- 7y ago
- DerSaidin 7y agoLooks like a nice concise list of key features for someone to reimplement.
- larnmar 7y agoFor me as a non-US person, this reads like a spec sheet for “here’s something you should build, because there’s customers waiting”.