Saving Free Speech from the ITAR

Tomorrow is the final day for public comments to the State Department’s Proposed “Harmonization” Rule, which seeks to explicitly require U.S. Government approval of public speech concerning technical data controlled by the International Traffic in Arms Regulations (“ITAR”). [F/N 1]  The Proposed Rule is perhaps the most troubling of those promulgated […]

Proposed Harmonization Rule: The Defense Service Problem

August 3, 2015 is the deadline for submission of public comments to the Department of State Directorate of Defense Trade Controls (“DDTC”) proposed rule at 80 Fed. Reg. 31,525 (June 3, 2015), which seeks to redefine “Public Domain,” “Defense Service,” “Fundamental Research,” and other key terms used in the International Traffic in […]

ECR Task Force Publishes 16th Amendment to STA

With publication of today’s Final Rule at 80 Fed. Reg. 39,950, the President’s Export Control Reform Initiative marks its sixteenth (16th) amendment to license exception Strategic Trade Authorization (“STA”) since initial implementation of the exception in June 2011. [F/N 1] The Final Rule somewhat unjumbles the Section 740.20(d) […]