4 ms·

I've tried to read the (currently unpublished) interim final rule to see what's been added but with all of the ECCN, country groups, and license exceptions cros

I've tried to read the (currently unpublished) interim final rule to see what's been added but with all of the ECCN, country groups, and license exceptions cross-referenced it's practically incomprehensible: [PDF] https://public-inspection.federalregister.gov/2021-22774.pdf https://public-inspection.federalregister.gov/2021-22774.pdf

tossaway9000 5y ago
There are lots of interesting bits in there though, such as: > List of Items Controlled > a. Any type of telecommunications equipment having any of the following characteristics, functions or features > a.2. Specially hardened to withstand gamma, neutron or ion radiation; is ECC memory now a controlled item?
- duskwuff 5y ago
  No. ECC memory isn't "hardened" in the technical sense intended here; it's simply error-detecting. What this primarily refers to is hardware which has been fabricated on an exotic semiconductor process (like silicon-on-insulator substrates) to resist radiation-induced upsets or latchup. This hardware is almost exclusively used in military and space applications; it's basically nonexistent in the consumer space.
  - thereddaikon 5y ago
    I wish it were but then again I'm not ready to spend $20k on a cellphone with performance from 2005.
    - idiotsecant 5y ago
      >I wish it were Why?
      - thereddaikon 5y ago
        Because its cool. Am I not allowed to want something because I think its neat? I don't need night vision goggles either but man it would be cool to walk around in the woods at night with them on and star gaze.
    - InitialLastName 5y ago
      Do you often find your devices facing issues from bit flips due to excess radiation?
      - netr0ute 5y ago
        This is actually a real concern, as more phones have gobs of RAM thanks to sloppy coding and marketers needing more and more space.
        ygjb 5y ago
        So that perspective is largely a risk management failure. Yes, it's possible and probably likely, that at some point a rogue cosmic ray might flip a bit on your phone (or a bit in transit between a tower and your phone). No, it is exceedingly unlikely that such a bit flip will have a real world impact beyond an unexpected error that manifests as an application crash or device reboot in the worst scenario, and most likely a temporary failure such as an image not loading or rendering, or a decryption operation that fails because the flipped bit makes is treated as an error. Is it something to be concerned about? Generally not - if you are in an environment that has sufficient radiation that it has a practical impact on your phone, one would hope that your actual concern is more heavily focused on protecting your physical self, and one would hope that your personal threat model increases in scope to justify spending on electronics that are more resilient if you have budget left over after buying protective gear.
        tossaway9000 5y ago
        Are there any means to detect that a cosmic ray caused such a crash without ECC memory? I recall that Drop Box had some issues early on with memory corruption due to how many low-end PCs ran Drop Box. I recall coming across a more detailed write up a long time ago but still found mention of the issue [0] > our clients rarely have ECC memory. We see a constant rate of memory corruption in the wild and end-to-end integrity verification always pays off. [0] https://dropbox.tech/infrastructure/-broccoli--syncing-faster-by-syncing-less https://dropbox.tech/infrastructure/-broccoli--syncing-faste...
  - speed_spread 5y ago
    Wasn't SoI standard in CPU production at some point in the last 20 years? AMD I think used it for Athlons.
    - duskwuff 5y ago
      You are correct! SoI was common for high-performance ICs in the early 2000s, but lost out to more conventional CMOS processes.
- stagger87 5y ago
  > is ECC memory now a controlled item? What you meant to ask is, "Is telecommunications equipment using ECC memory controlled under 5A001?", and the answer is no, a.2 refers to rad-hard components. The key words are "specifically hardened to ..." instead of something like "using any technology that might help with ...". Generally the CCLs never use vague wording like this.
averysmallbird 5y ago
The new controls are for "intrusion software" (e.g. malware) and "IP network communications surveillance systems or equipment." There are specific definitions for those terms with technical specifications. Then there are licenses/exemptions that mean you don't have to seek a license if you are selling to nongovernment customers in certain (friendlier) countries. There's also larger exemptions in export controls related to commercial off the shelf equipment and fundamental research that would apply as well. Generally the take away is that if you're selling malware, exploits, or network surveillance equipment, you might want to talk to an export control lawyer first.
nixpulvis 5y ago
Are there any nice tools for resolving cross references like this in a body of text? I don't deal with legal documents enough (luckily) to have ever really needed this, but it would be a nice thing to know how to use if needed, or on creative document sets. Essentially I'm asking for something where I can import a set of machine readable text (or OCR'd) set a grammar for references in context and then easily click through. If it's easy enough to extend the grammar I could probably link new things up as I go when new kinds of references pop up. Trying to get too smart about things like acronyms might be a step too far though, I want to be able to trust this tool completely.
- xxpor 5y ago
  Fwiw for actual bills, they're all written in an XML format that makes this easy. I don't think any executive branch agencies use it though, unfortunately.
  - dragonwriter 5y ago
    > Fwiw for actual bills, they're all written in an XML format that makes this easy. I don't think any executive branch agencies use it though, unfortunately Not the same XML format (s), but regulatory material (both Federal Register and CFR) is also published in XML. The Government Printing Office has a Bulk Data Repository with the machine readable (largely XML) forms of legislative, regulatory, and a bunch of other documents: https://www.govinfo.gov/bulkdata https://www.govinfo.gov/bulkdata

tossaway9000 5y ago

There are lots of interesting bits in there though, such as: > List of Items Controlled > a. Any type of telecommunications equipment having any of the following characteristics, functions or features > a.2. Specially hardened to withstand gamma, neutron or ion radiation; is ECC memory now a controlled item?

duskwuff 5y ago
No. ECC memory isn't "hardened" in the technical sense intended here; it's simply error-detecting. What this primarily refers to is hardware which has been fabricated on an exotic semiconductor process (like silicon-on-insulator substrates) to resist radiation-induced upsets or latchup. This hardware is almost exclusively used in military and space applications; it's basically nonexistent in the consumer space.
- thereddaikon 5y ago
  I wish it were but then again I'm not ready to spend $20k on a cellphone with performance from 2005.
  - idiotsecant 5y ago
    >I wish it were Why?
    - thereddaikon 5y ago
      Because its cool. Am I not allowed to want something because I think its neat? I don't need night vision goggles either but man it would be cool to walk around in the woods at night with them on and star gaze.
  - InitialLastName 5y ago
    Do you often find your devices facing issues from bit flips due to excess radiation?
    - netr0ute 5y ago
      This is actually a real concern, as more phones have gobs of RAM thanks to sloppy coding and marketers needing more and more space.
      - ygjb 5y ago
        So that perspective is largely a risk management failure. Yes, it's possible and probably likely, that at some point a rogue cosmic ray might flip a bit on your phone (or a bit in transit between a tower and your phone). No, it is exceedingly unlikely that such a bit flip will have a real world impact beyond an unexpected error that manifests as an application crash or device reboot in the worst scenario, and most likely a temporary failure such as an image not loading or rendering, or a decryption operation that fails because the flipped bit makes is treated as an error. Is it something to be concerned about? Generally not - if you are in an environment that has sufficient radiation that it has a practical impact on your phone, one would hope that your actual concern is more heavily focused on protecting your physical self, and one would hope that your personal threat model increases in scope to justify spending on electronics that are more resilient if you have budget left over after buying protective gear.
        tossaway9000 5y ago
        Are there any means to detect that a cosmic ray caused such a crash without ECC memory? I recall that Drop Box had some issues early on with memory corruption due to how many low-end PCs ran Drop Box. I recall coming across a more detailed write up a long time ago but still found mention of the issue [0] > our clients rarely have ECC memory. We see a constant rate of memory corruption in the wild and end-to-end integrity verification always pays off. [0] https://dropbox.tech/infrastructure/-broccoli--syncing-faster-by-syncing-less https://dropbox.tech/infrastructure/-broccoli--syncing-faste...
- speed_spread 5y ago
  Wasn't SoI standard in CPU production at some point in the last 20 years? AMD I think used it for Athlons.
  - duskwuff 5y ago
    You are correct! SoI was common for high-performance ICs in the early 2000s, but lost out to more conventional CMOS processes.
stagger87 5y ago
> is ECC memory now a controlled item? What you meant to ask is, "Is telecommunications equipment using ECC memory controlled under 5A001?", and the answer is no, a.2 refers to rad-hard components. The key words are "specifically hardened to ..." instead of something like "using any technology that might help with ...". Generally the CCLs never use vague wording like this.

averysmallbird 5y ago

The new controls are for "intrusion software" (e.g. malware) and "IP network communications surveillance systems or equipment." There are specific definitions for those terms with technical specifications. Then there are licenses/exemptions that mean you don't have to seek a license if you are selling to nongovernment customers in certain (friendlier) countries. There's also larger exemptions in export controls related to commercial off the shelf equipment and fundamental research that would apply as well. Generally the take away is that if you're selling malware, exploits, or network surveillance equipment, you might want to talk to an export control lawyer first.

nixpulvis 5y ago

Are there any nice tools for resolving cross references like this in a body of text? I don't deal with legal documents enough (luckily) to have ever really needed this, but it would be a nice thing to know how to use if needed, or on creative document sets. Essentially I'm asking for something where I can import a set of machine readable text (or OCR'd) set a grammar for references in context and then easily click through. If it's easy enough to extend the grammar I could probably link new things up as I go when new kinds of references pop up. Trying to get too smart about things like acronyms might be a step too far though, I want to be able to trust this tool completely.

xxpor 5y ago
Fwiw for actual bills, they're all written in an XML format that makes this easy. I don't think any executive branch agencies use it though, unfortunately.
- dragonwriter 5y ago
  > Fwiw for actual bills, they're all written in an XML format that makes this easy. I don't think any executive branch agencies use it though, unfortunately Not the same XML format (s), but regulatory material (both Federal Register and CFR) is also published in XML. The Government Printing Office has a Bulk Data Repository with the machine readable (largely XML) forms of legislative, regulatory, and a bunch of other documents: https://www.govinfo.gov/bulkdata https://www.govinfo.gov/bulkdata