I ran across the thread related to the question of ECCN and have a few 
questions:

*         Is the Debian OS that is freely downloadable source or object code

*         Based on the information you provided, I presume the Debian OS 
contains some embedded encryption functionality. Is this correct? If so, does 
this functionality come standard as part of the free download?
Thanks for your assistance.............Ron

Ron Devincenzi
Export Compliance Manager
JPMorgan Chase Global Trade Services
Ph: 845.297.0040
Cell: 845.527.5965
email: ronald.p.devince...@jpmchase.com


"Diehl Markus" <markus.di...@vierling.de> wrote in message 
7fb9a405f330794b932cffb6687384d901ec0...@vg-ms-2.vierling.corp<news:%3ca%20href=>">news:7fb9a405f330794b932cffb6687384d901ec0...@vg-ms-2.vierling.corp<http://lists.debian.org/debian-legal/2007/08/msg00069.html>...

Hello,



on one of our VoIP GSM gateways we use Debian/GNU Linux.

For export issues according to US law we require a so called ECCN code

for the gateway.

The ECCN code of our VoIP GSM gateway will be determined by the ECCN

codes of the used sub components (e.g. a ECCN code of the Linux system).

Is there an ECCN code for Debian/GNU Linux?



Best regards + Many thanks!

Markus






First of all, I am not a laywer. So the following is not legal advice, but only 
what i know.


I'm not aware of any ECCN that would cover an operating system as a whole. 
However, parts of Debian may be covered under ECCN 5D002. However, those parts 
fall under the TSU licence exception, so no licence is required for that 
component. I'm not sure of any other applicable ECCN. Also note that the ECCN 
of a GNU/Linux distribution can vary depending on what components of it are 
exported. (Your GSM gateway presumably does not use every component of Debian 
GNU/Linux).


Your safest bet would be to submit a classification request for the entire 
system to BIS, as described in the answer to question 3 at 
http://www.bis.doc.gov/Licensing/Do_I_NeedAnECCN.html




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