It sounds like most of their "counter-arguments" are just stalling tactics. If you are a lawyer for someone you know is guilty, you still would choose to find every reason in the book to attack the prosecution's case. Here we have precisely the same effect with the NSA. Any tactical manuveur to keep stalling the impending collapse of ITAR. (It is human .. er .. rather .. bureaucrat-esque to claim innocence in the face of overwhelming evidence of guilt.)
The NSA document also calls into question our cost estimates for ASIC components, suggesting that ASIC chips of this type cost NSA approximately $1000.00 each. However, our $10.00 per chip estimate is based on an actual price quote from a commercial chip fabrication vendor for a moderate-size order for an exhaustive search ASIC designed in 1993 by Michael Wiener [2]. Perhaps NSA could reduce its own costs by changing vendors.
Perhaps, in their fit of downsizing, Congress should privatize the NSA? Ern