Wednesday, September 2, 2020 at 22:22:57 Eastern Daylight Time 

Subject: (from Helena Keeley / Compsim) Explainable AI 

Date: Friday, August 21, 2020 at 11:17:49 AM Eastern Daylight Time 

From: Helena Keeley 

To: explainable-AI@nist.gov 

CC: 

To Whom it May Concern: 

We read your recent NIST RFI document on the subject of Explainable AI. 

We understand you are asking for comments and/or questions. 

Question: we aren’t sure of the wording that is used regarding Royality Free or Royalty-Bearing. 

We license our technology depending on the market value of the use of the patents. So for Compsim – regarding 

the cost of licensing -“it depends”... 

?? 

Our Comments: 

When we applied for the patents below, the term “Explainable AI” was not used. The patents are for 

technology that can be used anywhere human-like reasoning and judgment needs to be incorporated in machines. 

It is 100% auditable and explainable, so now we use the term “Explainable AI” all the time. When we developed our 

version of AI we felt explainable and auditable behavior was a necessity; not an option. 

In fact we were asked to write a chapter on the 2015 NATO book on Autonomous Systems: “Issues for Defence 

Policy Makers”: http://www.act.nato.int/images/stories/media/capdev/capdev_02.pdf Chapter 9: Auditable 

Policies for Autonomous Systems (Decisional Forensics). Starting at the book page 196. Chap 9 explains how 

KEEL Technology addresses the needs of autonomous systems. 

We didn’t see any references to our patents, so we thought you should know about them. Here is a list of the 

granted patents, and a brief sentence describing them. 

COMPSIM’s Granted Patent Portfolio: 

1.QUANTITATIVE DECISION SUPPORT PROGRAM (Patent # 6,833,842 issued 12/21/04) -This patent covers the 

decision-making mechanism used in Compsim’s Management Tools which provides the decision-making basis for 

KEEL technology 

2.COMPUTER PROGRAM AND DATA STRUCTURE FOR USE IN KNOWLEDGE ENHANCED ELECTRONIC 

LOGIC (Patent # 7,039,623 issued 5/2/06) - This patent covers the KEEL engine architecture 

3.COMPUTER PROGRAM AND RELATED DATA PROCESSING METHODS FOR USE IN KNOWLEDGE 

ENHANCED ELECTRONIC LOGIC (Patent # 7,009,610 issued 3/7/06) - This patent covers the KEEL decisionmaking algorithm and options in detail 

4.PROGRAMMING TOOLKIT FOR USE IN THE DEVELOPMENT OF KNOWLEDGE ENHANCED ELECTRONIC 

LOGIC PROGRAM (Patent #7,159,208 issued 01/02/07) - This patent covers the KEEL toolkit: User interface and 

underlying mechanisms 

5.ELECTRONIC CIRCUIT IMPLEMENTING KNOWLEDGE ENHANCED ELECTRONIC LOGIC (Patent #7,512,581 

issued 3/31/2009 ) - This patent covers the hardware implementation of KEEL 

6.MECHANISM FOR COMPLEX COGNITIVE RELATIONSHIP IMPLEMENTED WITH KNOWLEDGE ENHANCED 

ELECTRONIC LOGIC (Patent # 7,685,528 issued 3/23/2010) -This patent covers additional functional relationships 

to solve more complex problem sets. 

Another Comment - regarding the NIST whitepaper: 

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NIST 4 Principles of Explainable AI: 

Explanation: Systems deliver accompanying evidence or reason(s) for all outputs. 

KEEL DGL 100% 

Meaningful: Systems provide explanations that are understandable to individual users. 

KEEL (easy) 

Explanation Accuracy: The explanation correctly reflects the system’s process for generating the output. 

KEEL 100% because the DGL defines the policy that is executed. 

Knowledge Limits: The system only operates under conditions for which it was designed or when the system 

reaches a sufficient confidence in its output. 

The system architect will determine how and when cognition is executed within the system. The designer is 

in control. Confidence is exposed and under human (or other) control. As is controlling the “value system”. 

KEEL doesn’t care. 

Our thought is that the NIST authors must only be thinking about Machine Learning. KEEL Technology is an Expert 

System, but it is definitely AI. And, it’s Explainable AI. 

From the whitepaper’s terminology, KEEL would “kind of” fit in what is termed “Self-Explainable Models”. Our other 

observation is that the whitepaper’s examples are all “augmented human” examples, rather than autonomous 

system related (information rather than action). 

We look forward to hearing your response – any comments/answers would be appreciated. 

Regards, 

Helena 

Helena G. Keeley 

CEO - Compsim LLC 

Brookfield, Wisconsin 

Devices / Systems that can interpret information better and faster and can react better and faster will 

win. 

Organizations that control those devices / systems will win. 

Organizations that can accumulate these devices / systems faster will win. 

KEEL® Technology is covered by granted patents (6,833,842, 7,039,623, 7,009,610, 7,159,208, 7,512,581, 

7,685,528) and requires a license from Compsim for its use or evaluation. 

http://www.compsim.com 

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