"Letter to Secretary Lutnick Regarding Concerns Over Export Control Violations and National Security Risks Linked to Foreign Access to U.S. University Supercomputers"
March 6, 2025
The Honorable Howard Lutnick
Secretary of Commerce
1401 Constitution Ave NW
Washington, D.C. 20230
Dear Secretary Lutnick,
We write to request a briefing from the Bureau of Industry and Security (BIS) regarding the application of export control restrictions to the access of university or academic supercomputers that rely on export-controlled chips. Recent reporting has made clear that People’s Republic of China (PRC) entities, including companies implicated in China’s military modernization and human rights abuses, have attempted to circumvent U.S. export control restrictions by working through intermediaries to gain access to advanced computing centers powered by export-controlled chips.
Similar risks could arise in academic settings, where the PRC may seek to leverage access to supercomputers to gain a lead over America in artificial intelligence with military applications or other uses that threaten U.S. national security. For example, foreign nationals may seek access to a university supercomputer to perform research on behalf of an entity that is prohibited from accessing advanced semiconductor chips or to perform research that furthers the PRC’s military modernization goals and remit the results (including any resulting model) back to China. PRC nationals may also seek to gain information about the design or operations of these supercomputers while ostensibly using the supercomputer for research purposes. This activity could constitute a violation of export control regulations via an unlicensed deemed export.
Academic programs using supercomputers with advanced semiconductors are an important resource—one that students who are PRC nationals and not U.S. persons may be able to access. U.S. universities currently host 22 of the 500 most powerful computers in the world. In one example of potential concern, the University of Florida (UF) hosts the second most powerful of these U.S. university supercomputers, HiPerGator AI, with a performance (Rmax) of 17,200 teraFLOPS. HiPerGator AI uses Nvidia’s A100 graphics processing unit (GPU), a GPU legally restricted from export to the PRC. An assistant professor in UF’s computer science and engineering department who highlighted potential access to HiPerGator AI in recruiting posts in both English and Chinese-language forums currently supervises at least two Ph.D. students who are graduates of PRC universities on the BIS Entity List and three others who graduated from PRC universities flagged as medium or high risk for their work on defense research.
Organizations on the BIS Entity List are “deemed a national security concern,” and exports of certain technologies or products to those entities are subject to additional restrictions and licensing requirements. The University of Florida is currently assembling the next stage of its supercomputer capabilities, HiPerGator AI 2.0, which will use chips also restricted for export to the PRC: Nvidia’s just-released Blackwell GPU.
Access to supercomputers is part of what attracts students seeking to study advanced computing to American universities with these resources, but both PRC entities’ demonstrated desire to circumvent export controls on chips and the PRC’s history of exploiting academic institutions’ openness call for vigilance surrounding these important resources. PRC entities have sought to work around export controls on chips by remotely accessing computing assets abroad and importing export-controlled chips through indirect channels. The PRC has recruited and used students, particularly PRC nationals, to siphon expertise and technological development from the United States.
Through a range of talent recruitment programs, the PRC incentivizes Chinese nationals studying at U.S. universities and U.S. academics to extricate knowledge from the United States, directly and indirectly. Directly, students and other academics in these programs extract intellectual property from institutions and organizations in the United States. Indirectly, they acquire critical skills and knowledge in the United States and apply such knowledge and skills in PRC programs to compete militarily and economically with the United States. These highlight the importance of the guardrails related to accessing resources such as supercomputers at U.S. universities.
Accordingly, a briefing from BIS on the application of export control restrictions to access by PRC nationals to supercomputers at U.S. universities would aid our understanding of current national security risks to American technology.
The House Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party has broad authority to investigate and submit policy recommendations on countering the economic, technological, security, and ideological threats of the Chinese Communist Party to the United States and allies and partners of the United States under H. Res. 5 Sec. 4(a).
Thank you for your attention to this important matter.
Sincerely,
John Moolenaar
Chairman
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