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Re: [tdf-discuss] LibreOffice +US Gov't ECCN Export Control


----- Original Message ----

From: Robert Burrell Donkin <robertburrelldonkin@gmail.com>
To: discuss@documentfoundation.org
Sent: Sat, June 18, 2011 10:19:41 AM
Subject: Re: [tdf-discuss] LibreOffice +US Gov't ECCN Export Control

On Sat, Jun 18, 2011 at 10:27 AM, Uwe Altmann <ooo@altsys.de>  wrote:
Hi Garry

Am 17.06.11 23:45, schrieb  NoOp:
In the past I'd answered a few questions regarding OOo ECCN[1]  and
pointed the poster to Sun's ECCN[2]. What are the implications  for LO
general with regards to ECCN? I do see that Novell/Attachmate  Group do
list an ECCN for LO[3] with a category of  5D992.

Given that questions eventually will come up  regarding LO & ECCN by US
Government/Business  users,...

As I can see, the Export Control Classification Number  (ECCN) is an
issue dealing with /exports from US/.
AFAIK LO is  not a US Product nor exported from within US (not even
hosted there) and  therefore this should be a no-issue :-)

AIUI it would be a good idea for  the TDF to consult it's US legal team
about whether this is really the  case...


Very much so, especially since from what Export Control training I have had, 
even a patch from a developer in the US would be considered an export to TDF/LO 
and thereby require an export license. IANAL, and that may fly under the radar 
easily; but it is something to have the legal team consider.

Ben

P.S. Technically, by that same training, even a conversation with a non-US 
citizen is considered an export of information. Obviously not every export can 
necessarily be controlled. However, it may be wise to have patches and such 
reviewed to ensure things don't run afoul - e.g. by a developer submitting a 
patch that is export controlled (e.g. encryption). Again, IANAL; that is just 
how I've been trained on Export Control.


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