From: "William H. Geiger III" <whgiii@amaranth.com>
Date: Fri, 2 May 1997 04:08:00 +0800
To: Tim May <tcmay@got.net>
Subject: Re: SAFE Bill is a Disaster--"Use a cipher, go to prison"
In-Reply-To: <v03007801af8ea0d7d7df@[207.167.93.63]>
Message-ID: <199705011941.OAA10162@mailhub.amaranth.com>
MIME-Version: 1.0
Content-Type: text/plain


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In <v03007801af8ea0d7d7df@[207.167.93.63]>, on 05/01/97 at 01:40 PM,
   Tim May <tcmay@got.net> said:


>At 10:27 AM -0800 5/1/97, sameer wrote:
>>>
>>> Oh, and Sameer, those products you re-export, like Stronghold, may soon be
>>> banned by SAFE. It may not even be legal, even according to current law,
>>> for you to operate out of Anguilla.
>>
>>	We don't re-export anything. All development happens outside
>>the US, and all sales to customers outside the US happen from outside
>>the US. As far as operating from Anguilla -- it would require
>>renouncing my US citizenship, yes.

>I'm no expert in these areas, but doesn't this consitute "providing hooks"
>for strong crypto? The EARs say that a "hook" for inserting crypto modules
>once a product is exported are essentially as bad as providing the crypto
>before the product is exported.

>Also, my understanding is that U.S. companies cannot send experts or
>programmers to non-U.S. sites with the intention of thereby violating U.S.
>export laws. (I once asked Jim Bidzos why he did not simply move his key
>developers beyond the borders, and this is the answer he gave, repeated by
>others at later times on the CP and other lists. So far as I know, this
>has never been tested in court. Such a test would be comparable to
>Bernstein, Junger, Karns, etc. in significance.)

It is my understanding that not only is the above true but the financing of
the development of crypto off-shore is also made illegal by the new
restrictions. So if C2Net were to hire an independent foreign co. to
develop their international version it would be in volation of the current
regs even if no code was exported.


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William H. Geiger III  http://www.amaranth.com/~whgiii
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