There is a problem with these "hair splitting" approaches to avoiding the ITARs (they accept the book; they reject the disks, so we ask to send some- thing that is halfway between the book and the disks, etc.). There is a well-known fallacy (whose fancy name I don't remember) which says that even though night and day change gradually from one to the other, and you can't really draw a line separating night from day, that doesn't change the fact that night is different from day. We may establish that hitting someone with a baseball bat is against the law, and hitting them with a feather is not; then we proceed to ask whether hitting them with a pillow is against the law, and so on. At some point the law is forced to make an absurd decision that hitting someone with item X is illegal while hitting them with Y is not, but X is almost the same as Y. Does this prove that no amount of assault is illegal? No. It just means that lines are not always easy to draw. In the same way, it is not easy to draw a line between a book which is protected by the first amendment and a program which a person can sit down and run to get military grade cryptography. But that does not lead to a strong legal argument that all cryptographic software is export- able, IMO. Hal