News

USIS Washington 
File

10 May 1999

TEXTS: COMMERCE, JUSTICE STATEMENTS ON ENCRYPTION RULING

(Export controls remain in force, agencies warn) (760)

Washington -- The Commerce and Justice departments have issued
statements warning exporters that controls on encryption software
exports remain in force at least until federal U.S. courts take
further action.

At issue is the government's prohibiting University of Illinois
Professor Daniel Bernstein from publishing on the Internet an
encryption program called Snuffle that he developed while an
undergraduate at the University of California. The State Department
had ruled that making the program available on the Internet required
the same kind of export license as is issued for a munition.
 
A U.S. Court of Appeals panel in San Francisco ruled 2-1 May 6 that
the export controls violated Bernstein's First Amendment right to
freedom of speech.

A government appeal to the full Court of Appeals and perhaps
eventually the Supreme Court is considered likely.

The Commerce Department's Bureau of Export Administration (BXA) and
Justice Department said in their statements that encryption export
controls remain in force until the Court of Appeals issues an order in
45 days or more. They said the controls will remain in force longer if
the government appeals the ruling.

Following is the text of the BXA statement:

(begin text)

BXA Statement on Encryption Case
May 6 Court Decision in Bernstein Encryption Case

You may have read about a recent court decision regarding encryption
exports. Please be advised that this decision does not mean that
encryption products may be exported without regard to the Export
Administration Regulations (EAR). Regardless of how the decision might
be interpreted, the decision is subject to a stay. This stay is in
effect for at least 45 days. (See Department of Justice press
release.)

On May 6, the U.S. Court of Appeals for the Ninth Circuit rendered a
decision in Bernstein v. The United States Department of Justice.
Professor Daniel Bernstein filed suit against the U.S. Government
after he was notified by the State Department that his "Snuffle"
encryption program was subject to the International Traffic in Arms
Regulations (ITAR) and would require an export license to post the
source code on the Internet. Bernstein subsequently amended his
petition to challenge the controls on encryption products maintained
under the EAR after President Clinton placed encryption exports under
the Commerce Department's jurisdiction in 1996. In a 2-1 decision, the
Ninth Circuit court upheld the district court's decision that the
regulation of Bernstein's export of his "Snuffle" program
"constitute[s] an impermissible prior restraint on speech."

Exporters should be aware that the decision does not affect the
applicability of the EAR to exports and reexports of encryption
hardware and software products or encryption technology. This includes
controls on the export of encryption software in source code. The EAR
remain in effect for these items. The Commerce Department will apprise
exporters of any changes to the encryption controls.

(end text)

Following is the text of the Justice Department statement:

(begin text)

Department of Justice Statement
On Ninth Circuit Court of Appeals Decision in Encryption

On May 6, a three-judge panel of the United States Court of Appeals
for the Ninth Circuit in San Francisco issued a decision in a case
involving government controls on encryption exports. The Department of
Commerce and the Department of Justice are currently reviewing the
Ninth Circuit's decision in Daniel Bernstein v. United States
Department of Justice and United States Department of Commerce. We are
considering possible avenues for further review, including seeking a
rehearing of the appeal en banc in the Ninth Circuit.

The regulations controlling the export of encryption products
currently remain in full effect. The Ninth Circuit's decision will not
take effect until the court issues its mandate, which will not occur
for at least 45 days. If the government asks the Ninth Circuit to
rehear the appeal during that time, the mandate will not issue until
after the Ninth Circuit has acted on the government's request.

The district court injunction in this case relating to the encryption
export regulations has been stayed by orders issued earlier by the
district court and the Ninth Circuit, and the stays of the injunction
remain in effect until the mandate issues. Accordingly, all persons
who wish to engage in encryption export activity, including the
posting or other distribution of encryption software on the Internet,
must still comply with the export licensing requirements of the Export
Administration Regulations, administered by the U.S. Department of
Commerce's Bureau of Export Administration (BXA).

Information about the regulations is available at the BXA website at
www.bxa.doc.gov.

(end text)