Export Controls

So, I was reading over a superficial summary of U.S. export controls
today, and discovered
that radio receivers capable of more than 1000 channels (what the heck
is a channel?) and
able to switch channels in under 1ms are export-controlled technology.

It seems to me that a USRP with a Gnu Radio filterbank in the back-end
is such a receiver,
and is thus subject to U.S. export control.

Anyone with a better view of this able to comment?

Marcus L. Mail: Dept 1A12, M/S: 04352P16
Security Standards Advisor Phone: (ESN) 393-9145 +1 613 763 9145
Strategic Standards
Nortel Networks [email protected]

Marcus L. schrieb:

Anyone with a better view of this able to comment?
I only have my cynical view of the US government, and similar
regulations that made
‘encryption’ an armament… on the other hand as an arms, every 'murkin
citizen has
the right to bear arms… and hence, by declaring encryption an
armament, every
'murkin has a right to encryption… where’s the NRA when ya need 'em…

By similar reasoning then, every 'murkin has a right to a myriadchannel
radio receiver…

As for needeing a filter bank… with DSP there is no need for a ‘filter
bank’… at least as
a physical element…

And of course it is with good reason we, us 'murkins, get all of our
manufactured products
from China, since we then don’t have to worry about US export
regulations at all.

It seems to me that a USRP with a Gnu Radio
filterbank in the back-end is such a receiver,
and is thus subject to U.S. export control.

That part of the law is meant to deter the export of
radios what can be used for surveillance of things
like cell phone frequencies. For example, CDMA uses a
puedorandom frequency hopping technique whose
switching speed is inversely proportional to the data
rate. Even at the low end of CDMA (14.4 Kbps) this is
less than 1ms.

AFAIK GNU Radio and the USRP fall in to the category
of “Test Equipment”.

To be under export restrictions GNU Radio would need
to be equipped with a USRP, an extremely fast computer
(which would also be under export control), an
implementation of a scanner that supported things like
CDMA, G3, etc, or a the very least a software scanner
that did not omit restricted frequencies (much like
civilian scanners). (As an aside, CDMA would also
require royally fees to Qualcom. :o )

Things like Spectrum analyzers and wide band tuners
are currently considered “TEST Equipment”.


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In the early days of the “encryption is an armament” issue, Phil Karn
produced DES code that was widely distributed. He was harassed for
having done so. I was asked to comment on all of this at the time
because Phil was one of my best friends at the time (and continues to
be) and I worked on the other side of the fence. I argued that it
was an unsupportable position on the part of the U.S. government from
practical viewpoints rather than idealistic (even though I was very
idealistic about having my friend harassed!). In the end, the code was
distributed inside the book on a floppy and as such was covered by rules
that applied to books. It was all just so silly. It was inevitable
that all that could be accomplished by the U.S. government was a
tactical retreat. The tactical retreat involved no more than a
delaying action. The delaying action lasted for a bit longer and the
export controls were soon called into serious question and as I
repeatedly warned, they were soon found to be unsupportable and

My OPINION is that the USRP is not a filterbank. If the USRP is a
filterbank then Altera, Xilinx, Quiklogic, etc. are going to have to
stop selling FPGAs and CPLD’s!! The software is a filterbank. The
software is published and therefore already exported. It is a fait
d’accompli. Matt could have a partnership outside the U.S. to produce
the boards and sell it for him. Since he has published all his
designs, they are already exported. There is no reasonable action that
can be taken and Matt has friends in and out of government that would
support him. The U.S. government, through several projects, is moving
to actively support GnuRadio, USRP, etc. under the same rules that
apply to all other members/contributors with assignments to FSF, etc.
ITAR and other pieces of similar legislation will eventually fall under
the weight of a) unenforceable and b) detrimental to U.S. corporate
competitiveness IMHO.


Marcus L. wrote:

Anyone with a better view of this able to comment?

AMSAT VP Engineering. Member: ARRL, AMSAT-DL, TAPR, Packrats,
Time for a new motto, what should I choose?

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