I don't understand basic legal writing, you you may very well be right. I would be nervous about fulfilling a contract or building a company with, for example, my code base, which is heavily built with deepseek

I understand basic legal writing very well (I went to school for it, though I don't practice) and I think you're dead wrong. 'third-party products and services developed using DeepSeek implementations' (used consistently in the text of the rule) is deliberately broad and indicate a refusal of all derivative products, not just offerings of the DS models provisioned on OpenRouter or suchlike.

Now, most software products developed with DS can pass an audit, whether human or from a US AI provider, that they do what they say and aren't secretly funneling telemetry to Beijing. When I say 'most..can pass an audit' I mean that most products are simple enough to undergo such an audit, rather than implying that some have exfiltration mines buried within; it's possible but I have have no reason to think it's probable. I believe the purpose of the broad wording is to facilitate the waiver requirement, which costs money to apply for and will require payment to an accredited or government approved audit provider, thus generating DSP on the US balance sheet even if the original prototyping/buildout was done with Deepseek.

footnote 10 says it includes 3rd party implementations of DeepSeek