E, EROS export status -- answers

shapj@us.ibm.com shapj@us.ibm.com
Fri, 21 Jan 2000 06:13:27 -0500


I now have an answer to Chip's question.

770.2(n) reads in part "... subsequent bundling, patches, upgrades, or
releases, including name changes, may be exported .... without further
technical review as long as the functional capacity of the originally
reviewed encryption product has not been modified or enhanced."

This applies only to binary code. Source code is assumed to be exempted
from such things in general under 740.13(e)(1)

Jonathan S. Shapiro, Ph. D.
Research Staff Member
IBM T.J. Watson Research Center
Email: shapj@us.ibm.com
Phone: +1 914 784 7085  (Tieline: 863)
Fax: +1 914 784 6576