The Software & Information Industry Association (SIIA) submitted comments to the Antitrust Division addressing the state of competition in the AI ecosystem, emphasizing that generative AI is still in its early stages but showing strong competitive dynamics. The letter highlights the significant innovation and rivalry among market participants, which benefits consumers through enhanced value, service, and choice. It discusses the key components of the AI stack—compute resources, data, storage, models, and talent—illustrating how they interrelate to form the AI value chain. The letter stresses that an aggressive enforcement approach could stifle innovation and recommends a balanced competition policy.

The letter also identifies potential barriers to entry in the AI market, such as the high cost of compute resources, access to robust data, and the need for skilled talent. While these barriers exist, the letter argues that the cloud industry, which underpins the AI ecosystem, is dynamic and highly competitive, offering significant benefits like scalability, flexibility, and democratized access to technology. The letter concludes by advocating for careful consideration of competition policies to avoid hindering the rapid growth and evolution of the AI market.