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From Ted Dunning <ted.dunn...@gmail.com>
Subject Re: ECCN page: http://www.apache.org/licenses/exports/ - broken links
Date Thu, 05 May 2016 17:08:53 GMT
Alex, thanks much.  That helps.



On Wed, May 4, 2016 at 10:26 PM, Alex Harui <aharui@adobe.com> wrote:

>
>
> On 5/4/16, 10:11 PM, "Ted Dunning" <ted.dunning@gmail.com> wrote:
>
> >
> >But do any of them have crypto *implementations*?
>
> I don't know, but this page [1] makes me think there is more to it than
> whether there is an "implementation" in the bundle, although I guess it
> also depends on your definition of "implementation".
>
> "Almost all items controlled under Category 5, Part 2 of the EAR are
> controlled because they include encryption functionality. Items may be
> controlled as encryption items even if the encryption is actually
> performed by the operating system, an external library, a third-party
> product or a cryptographic processor. If an item uses encryption
> functionality, whether or not the code that performs the encryption is
> included with the item, then BIS evaluates the item based on the
> encryption functionality it uses.
>
> Similarly, if the item includes encryption functionality, even if the
> encryption functionality is not used by the item, then BIS evaluates the
> item based on the included encryption functionality."
>
> [1]
> https://www.bis.doc.gov/index.php/policy-guidance/encryption/identifying-en
> cryption-items
>
> -Alex
>
>

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