UNITED STATES DEPARTMENT OF COMMERCE
                        The Under Secretary for Export Administration
                        Washington, D.C. 20230

                        December 4, 1998


Mr. Lee Tien, Esq.
1452 Curtis Street
Berkeley, CA 94702

Dear Mr. Tien:

I have reviewed your appeal, dated July 30, of the reclassification of the
Integrated DNSSEC (the software) from EAR99 to ECCN 5DO02 (Appl. Ref. No:
Z066051/GOO6298). Before I can decide your appeal, I must address,
preliminary matters that you have raised.

First, you have requested that we provide you with additional information
about the decision to classify this product as 5DO02 including:

	"(i) The actions taken by BXA on the initial classification
request, which resulted in the EAR 99 classification;
	(ii) The actions taken by BXA on the reclassification to ECCN
5DO02; and
	(iii) The train of events that led to BXA's revisiting this
classification in the first place."

For the most part, this information is not relevant to the review and
decision of this appeal. The issue here is whether the software is now
properly classified as 5DO02. The licensing office changed its
classification because it believes that the software should be now, and
should have been 5DO02. Whether that determination is correct is the issue
in this appeal.

While the facts surrounding the original classification are not relevant,
they are fully set out in the declaration of James A. Lewis in the Karn
case. Since you quote from this declaration, I presume that you have a copy
of it. If you are interested in questions such as what prompted the
licensing office's review, you should consult that declaration.

You have also asked that there be an informal hearing in this matter. It is
my policy to grant requests for such hearings.  I have designated
Anstruther Davidson, our appeals coordinator to preside over a hearing.
Please call him on 202-482-1149 to arrange a time for the hearing.  The
hearing will be held at BXA's offices in Washington, D.C.

Finally, you have asked to supplement your appeal papers. While I see
little need for this, I will consider anything else you wish to submit in
writing. You may wait to submit additional material until after the
informal hearing if you would like,

      Sincerely,
	/s/
   William A. Reinsch