Does it have to be written in this fashion? The PGP community defeated US export restrictions in the past by literally printing books filled with source code. Books are protected free speech in the US.
> One of the noteworthy features of the novel CRYPTONOMICON is that it contains a new cryptosystem invented by Bruce Schneier, called Solitaire. [...] Since Solitaire is strong enough to be subject to U.S. laws governing export of crypto technology, this means that when the text of the novel is rendered in electronic form it becomes an export-controlled good.
They relaxed that restriction shortly afterward, so Neal got to have his cake (having his ebook classified as weapons-grade), and eat it too (sell it anyway).