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Intelligence analysis is a cognitively complex task that is the subject of considerable research aimed at developing methods and tools to aid the analysis process. To support such research, it is necessary to characterize the difficulty or complexity of intelligence analysis tasks in order to facilitate assessments of the impact or effectiveness of tools that are being considered for deployment. A number of informal accounts of "What makes intelligence analysis hard" are available, but there has been no attempt to establish a more rigorous characterization with well-defined difficulty factors or dimensions. This paper takes an initial step in this direction by describing a set of proposed difficulty metrics based on cognitive principles.