Afaik Phil Zimmermann was one of the first to do it, in '95 through MIT Press—when his PGP circulated a bit too widely for the export regulations. However, the

Afaik Phil Zimmermann was one of the first to do it, in '95 through MIT Press—when his PGP circulated a bit too widely for the export regulations. However, the question of him being protected under the 1st wasn't decided in the court.