If this standard was applied across the industry, we believe it would essentially halt all new model deployments for all frontier model providers.

b. Identify legally relevant facts, t hat is, those facts that tend to prove or disprove an issue before the court. The relevant facts tell what happened before the parties enter ed the judicial system. c. Identify procedurally significant facts. You should set out (1) the cause of action (C/A) (the law the plaintiff claimed was broken), (2) relief the plaintiff requested, (3) defenses, if any, the defendant raised.

Identify the relationship/status of the parties (Note: Do not merely refer to the parties as the plai ntiff/defendant or appellant/appellee; be sure to also include more descr iptive generic terms to identify the relationship/status at issue, e.g., buyer/seller, employer/employee, landlord/tenant, etc.)