“The charging letter states that between April 2021 and August 2025, Lambda's server transmitted 42 automatic updates of TracePro and five updates of Oslo to Huawei Japan... each individual automatic update is considered a distinct technology transfer.”

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

sent automatic software updates to Huawei Japan via a server cron job, without per-instance authorization

42 automatic updates of TracePro and 5 updates of Oslo between April 2021 and August 2025

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