My BIS/Wassenaar comment
This is my comment I submitted to the BIS on their Wassenaar rules:----
Hi.
I created the first “intrusion prevention system”, as well as many tools and much cybersecurity research over the last 20 years. I would not have done so had these rules been in place. The cost and dangers would have been too high. If you do not roll back the existing language, I will be forced to do something else.
After two months, reading your FAQ, consulting with lawyers and export experts, the cybersecurity industry still hasn’t figured out precisely what your rules mean. The language is so open-ended that it appears to control everything. My latest project is a simple “DNS server”, a piece of software wholly unrelated to cybersecurity. Yet, since hackers exploit “DNS” for malware command-and-control, it appears to be covered by your rules. It’s specifically designed for both the distribution and control of malware. This isn’t my intent, it’s just a consequence of how “DNS” works. I haven’t decided whether to make this tool open-source yet, so therefore traveling to foreign countries with the code on my laptop appears to be a felony violation of export controls.
Of course you don’t intend Continue reading