Subject: Re: New encryption regulations
From: "D.V. Henkel-Wallace" <gumby3@zembu.com>
Date: Thu, 13 Jan 2000 15:25:54 -0800

At 17:50 13-01-00 -0500, Frank Hecker wrote:
>"D.V. Henkel-Wallace" wrote:
> > Hence, as I read this: anyone
> > planning to post gratis crypto source code needs to notify the
> > government -- and every time you update the file.
>
>Well, 740.13(e)(1) does require notifying the government initially "by
>the time of export", but I personally don't read it (or anything else in
>740.13(e)) as requiring notification every time you update the file. I
>can't find any language in the EAR (old or new) that specifically
>addresses this issue; did you?  (However note that for binaries exported
>under the ENC license exception, 770.2(n), "Interpretation 14", says
>that upgraded versions do not require further review as long as the
>relevant encryption functionality has not been modified or enhanced.)

I don't have the full proposal in front of me.  Do they define "initial?"

This is great if libre software is explicitly excepted from this nonsense.