Note that neither Title III (law enforcement) nor FISA (U.S.-based) apply to this situation, [...] I have to conclude that NSA would not be putting this technology out into the world *unless* it did, in fact, have some way to decrypt messages *without* access to the escrow keys.

Which is why they probably already have a draft for a bill to get escrowed keys without a warrant for national security reasons. They would want the whole escrow process set up before they announce this, of course. If they can't get this kind of bill passed, then they probably will not approve the technology for export. Alternatively, the escrow process may be written with specific wording that it applies only to US citizens leaving a convenient escrow process trap-door. This makes the Privacy Clipper difficult to sell overseas, but specially made chips for export might be compromised anyway with weak random seeds. Paul E. Baclace peb@procase.com