Dear Ms. Williams: This letter provides comments on the proposal to amend the Defense Federal Acquisition Regulation Supplement (DFARS) published in the Federal Register on July 12, 2005 (DFARS Case 2004—D010). The proposed rule contains a new DFARS Subpart 204.73, “Export-Controlled Information and Technology at Contractor, University, and Federally Funded Research and Development Center Facilities,” and an associated contract clause (DFARS Part 252.204—70XX). It closely reflects the recommendations in the March 25, 2004 report of the Department of Defense (DOD) Inspector General (IG), Export-Controlled Technology at Contractor, University, and Federally Funded Research and Development Center Facilities (D-2004-061).

The Association of American Universities (AAU), which represents 60 leading U.S. research universities, appreciates the opportunity to comment on the Notice of Proposed Rulemaking (NPRM) to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to address requirements for preventing unauthorized disclosure of export-controlled information and technology under DOD contracts (DFARS Case 2004-D010).

DoD is proposing to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to address requirements for preventing unauthorized disclosure of export-controlled information and technology under DOD contracts.