Comment from Information Technology Industry Council (ITI)

Summary: The Information Technology Industry Council (ITI), a technology trade association, opposes the proposed rule because it significantly increases prevailing wage benchmarks using "blind benchmarking" that ignores education, experience, and total compensation (like equity). They argue the proposal will harm entry-level STEM hiring and critical AI talent, and they instead recommend using an "experience benchmarking" methodology or preserving the use of private wage surveys.