Export Control Question re: Apache Crimson
2010-05-18 14:27:15 GMT
I’m assisting a client with the export classification of their product and the subject product utilizes Apache Crimson v.1.1.3. Do you know who might be the correct developer(s) for this open source code? If it’s you all, do you happen to know what the Export Control Classification Number (ECCN) for this code? If you don’t know the ECCN, can you please respond to the following questions at your convenience?
a. Does the code perform cryptographic functions (i.e., encryption/decryption)?
b. Does the code contain any cryptographic algorithms (i.e., 3DES, Diffie-Helman, Blowfish, Rijndael, RC4, RSA) (whether or not these algorithms are actually being used by the software)?
c. Is the code capable of interfacing with, calling to, using, invoking or enabling/disabling the cryptographic features within other software or within the underlying platform in any way?
d. Is the code capable of performing message digesting/hashing (i.e., MD5, RIPEMD, SHA, Tiger), fixed data compression or authentication?
e. Does the code contain/utilize and open cryptographic interface (OCI), where the cryptographic capabilities of the code are user-accessible and/or modifiable? (See below for a more detailed definition of OCI.)
If ‘yes’ to any of the above, please provide detailed response.
(Open cryptographic interface - A mechanism which is designed to allow a customer or other party to insert cryptographic functionality without the intervention, help or assistance of the manufacturer or its agents (i.e., manufacturer's signing of cryptographic code or proprietary interfaces). If the cryptographic interface implements a fixed set of cryptographic algorithms, key lengths or key exchange management systems, that cannot be changed, it will not be considered an "open" cryptographic interface. All general application programming interfaces (i.e., those that accept either a cryptographic or non-cryptographic interface, but do not themselves maintain any cryptographic functionality) will not be considered "open" cryptographic interfaces either.)
Please let me know if you have any questions for me and many thanks in advance for your assistance.
Export Compliance Manager
Sandler & Travis Trade Advisory Services, Inc.
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