Rodger, William writes:
> Based on a conversation I had with Commerce Undersecretary William Reinsch
> last night, as well as other crypto-savvy attorneys, I think it's probably
> more useful to look at the first page of the draft. Open Source code,
> believe it or not, would be essentially decontrolled by this proposal.
Essentially. You have to tell them you're publishing it, but that's
not a prior restraint, and there's no provision for denying you your
freedom to publish. You also have to (somehow) prevent users from
Cuba, Iran, Iraq, Libya, North Korea, Sudan and Syria form downloading
the code. Personally, I'd just check the domain name on the reverse
DNS, and if it's one of the above, shunt them aside. If anyone thinks
that's not sufficient, then the onus is on them to define what is.
I wonder if they've thought about the fact that in Perl, the source
code *is* the product ("any encryption product developed with source
code released under this provision is subject to the EAR (see Section
740.17).") And if one can export the source code, one is exporting an
encryption product without reference to the EAR.
--
-russ nelson <[EMAIL PROTECTED]> http://russnelson.com
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