United States Department of Commerce
					Bureau of Export Administration
					Washington, D.C. 20230

					Jun 19 1998 [stamped]

Appl. Ref. No.:  Z066051/G006298

Dear Mr. Tien:

The Bureau of Export Administration (BXA) has reviewed the classification
issued to you on June 6, 1997 for the Integrated DNSSEC program
(Application Reference No. Z066051 / G006298).  As you know, based on the
information provided at that time, BXA's classification concluded that the
program was classified as EAR99, given our understanding that the program
could only be used to authenticate users or messages.  However, a second
review has led BXA to determine that the program was not classified
appropriately.  Classification No. Z066051 / G006298 is hereby withdrawn.

The Integrated DNSSEC program is properly classified as ECCN 5D002 and
controlled for EI reasons because it includes the source code for RSAREF,
which can be used not only to encrypt files for authentication but, with
minimal effort, to also encrypt data for confidentiality purposes.  A
license is required under the Export Administration Regulations for the
export of Integrated DNSSEC to all destinations, except Canada.

We also note that the program is available on your client's website without
any precautions to prevent its unauthorized transfer outside the United
States.  Section 734.2(b)(9) of the Export Administration Regulations
defines the export of encryption source code and object code software to
include "making such software available for transfer outside the United
States . . . including transfer from World Wide Web sites" without taking
appropriate precautions.  Accordingly, since the program is classified
under ECCN 5D002, your client must take precautions adequate to prevent the
unauthorized transfer of encryption source code and object code software
controlled for EI reasons under ECCN 5D002 from that website.  Failure to
do so constitutes a violation of the Export Administration Regulations.  I
refer you to Section 734.2(b)(9) of the Export Administration Regulations.

If you have any questions regarding this matter, please contact Ms.
Patricia M. Sefcik, Director of the Encryption Policy Controls Division, at
(202) 482-0707.



				James A. Lewis
				Office of Strategic Trade and
					Foreign Policy Controls