On Thu, Dec 17, 2020 at 2:46 PM David Rowe <[email protected]> wrote:

> I've found in the past the Australian law in this area tends to be closely
> aligned with the US.
>

The USA takes their law on defense, intellectual property, etc. and puts it
in a treaty for other nations to sign onto. And you don't get
most-favorable trading partner status for your country, or defense
assistance, etc. if you don't sign on to those things. Of course, some of
it is actually in your interest. I don't want to give missiles to North
Korea. But a lot of it is to push an intellectual property regime that
doesn't really work in the interest of Open Source projects.

This is not legal advice, show this to a lawyer who is admitted to the Bar
Association and licensed in your state, and contracted to you. That is the
only person who can render legal advice to you (under the law where I am).

While there is indeed a "public domain" exemption in both ITAR and EAR, the
ITAR one doesn't actually count publication on the internet as a means of
placing art in the public domain. It thus is to your advantage to publish
scientific papers and get them accepted to journals. It also helps to get
the source code on a CD (for example a Linux distribution) that is publicly
available. I go into publication strategies in depth at
https://www.openresearch.institute/itar-and-ear-strategy/

My reading of ITAR 120.9 is that if you render aid to a foreign defense
project, whether the work is in the public domain or not, you're providing
a defense service as defined below, and thus potentially in violation of
the law:

§120.9   Defense service.

(a) Defense service means:

(1) The furnishing of assistance (including training) to foreign persons,
whether in the United States or abroad in the design, development,
engineering, manufacture, production, assembly, testing, repair,
maintenance, modification, operation, demilitarization, destruction,
processing or use of defense articles;


Regarding what technologies are restricted by ITAR, the part applicable to
the project is in the United States Munitions List, Category XI, Military
Electronics, item 18: *Parts, components, or accessories specially designed
for an information assurance/information security system or radio
controlled in this subchapter that modify its published properties (e.g.,
frequency range, algorithms, waveforms, CODECs, or modulation/demodulation
schemes);*

So, what's a radio "controlled in this subchapter"? Explicitly stated are a
spread-spectrum radio providing a low probability of interception, a laser
communicator, or a VLF radio that could potentially get a signal
underwater. So, there is context necessary. But this does not state a
bandwidth, and the SM-1000 can very easily be connected to one of the
restricted devices.

The Commerce Control List (used for EAR) has the text that got to Australia:

Section 5 - Telecommunications, item b.6. *Employing functions of digital
“signal processing” to provide 'voice coding' output at rates of less than
700 bit/s. *

So, there are potential complications under both ITAR and EAR. Thus, it's
important to maintain the "public domain" nature of the project, and not
render aid to defense projects.

    Thanks

    Bruce
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