None of them have asserted that export controls apply to whatever domestic distribution the administration says that never leaves the country.

Before you offer legal advice, you should at least check the legal definition of "export":

> The EAR definition of “export” extends beyond the transportation of physical goods outside the U.S.

> A “Deemed export” is the release of technology or source code to a foreign national in the U.S. The release is “deemed” to be an export to the last permanent residence status/citizenship of the foreign national. This can occur through demonstration, oral briefing, site visit, or through transmission of non-public data.

Ref: https://exportcontrol.lbl.gov/training/export-control-overvi...