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> Presumably this is going to be FPGA-based which brings up all the fun questions of how ITAR applies to software.

I mean there's plenty of prior art with open-source crypto implementations here.

Crypto is its own category in the ITAR, one whose impact decreased over time as events made the restrictions less relevant. Most crypto is now EAR not ITAR, but treated as a special category. I'm not sure the software classification lessons are going to apply.

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