Silverado submitted comments to the Office of the US Trade Representative on its proposed modifications to the Section 301 Tariffs, citing that since most chips are imported in downstream products like electronics, the tariffs would be more effective at combating China's nonmarket practices if they were imposed on semiconductors that: (i) are designed by a Chinese-headquartered company and/or Chinese majority-owned or controlled company; and (ii) are manufactured in China; (iii) whether or not they are incorporated into a downstream article. China’s rapid growth in the design and fabrication of "foundational" (also known as "legacy" semiconductors), fueled by massive government subsidies, is a matter of national and economic security.