In this letter, we respond to the BIS request for comments regarding the impact that a deemed export control would have if it was applied to the quantum items and the General
License were removed in this rule or at a future date. We also comment on how to address national security concerns in the absence of deemed export licensing requirements. Finally, we comment on the Implemented Export Control (IEC) license exception framework and the scope and clarity of the quantum-related Export Control Classification Numbers (ECCNs) added to the Commerce Control List (CCL).