In February 2023, U.S. Commerce Secretary Gina Raimondo was deciding whether or not to sign off on a Notice of Funding Opportunity (NOFO) for $39 billion in direct semiconductor manufacturing incentives. But this NOFO had several unconventional provisions: a pre-application (pre-app) to the actual application, upside sharing provisions to align incentives, and funding milestones so that only awardees making progress would receive additional funds. The funding had been made available through the U.S. Department of Commerce by the CHIPS (Creating Helpful Incentives to Produce Semiconductors) and Science Act passed a few months earlier. Raimondo’s team had proposed additional measures that would help the U.S. regain technological leadership while protecting taxpayer funds. Should Raimondo move forward with the “innovative” NOFO, despite the risks?