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From Nick Burch <>
Subject Re: Ready for ODF Toolkit crypto declaration
Date Wed, 15 Feb 2012 12:02:11 GMT
On Tue, 14 Feb 2012, Rob Weir wrote:
> If I understand correctly, since we are not including Java Crypto API 
> libraries in our code, we don't need to declare them specifically. But 
> since we're "designed to use" such libraries we need to register the ODF 
> Toolkit as 5D002.

I think this case is actually a 5x992 one, rather than a 5d002 one, but 
the rules did change fairly recently and we're in the process of figuring 
out the new policy.

> Note that we do have our own implementation of PKCS #5, per RFC 2898.
> This is a "password-based key derivation function", which is applied
> prior to encryption in order to convert "weak" passcodes entered by
> end users into higher entropy ones.   I don't see this as restricted
> under the export regulations, so I don't think we should declare it.

I think that's correct. What you feed the password bytes too may well be 
5D002 / 5x992 restricted (or similar), but I don't think the work to turn 
the string into bytes is

> Looking at the process [1] for doing this paperwork, it looks like we
> need to update this [2] page by updating this [3] source.
> [1]
> [2]
> [3]

Those guides refer to the old system, and are probably not now appropriate 
for this case. What should now be done is being discussed on the 
legal-discuss list:

Are you able and willing to put a bit of work in on this?  The 5d002 and 
based-on-5d002 cases are going to be a bit harder, but the 5x992 case 
(like this one) ought to be simpler. It does need someone to read up on 
the rules, check if the current understanding on legal-discuss looks 
correct, verify this with the BIS, and then finally we can update the 


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