“Lambda utilized a Japanese distributor to mail physical code meter USB dongles... they assumed mailing a physical USB dongle with a license key wasn't technically exporting the restricted software.”

Trade Compliance Brief - Export Control and Sanctions Insights · BIS Enforcement Analysis Lambda Research Corp Case: EAR99 Software Updates, Access Information, and Entity List Risks

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What was described

mailed physical USB dongles containing license keys to Huawei Japan, assuming the physical key was not an export

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