U.S. regulations of computing equipment, software, and technology exports fall largely under Category 4 of the Commerce Control List. However, some items may fall elsewhere, such as within telecommunications or encryption controls. We help clients assess the licensing requirements for their products and technologies and assist them in filing the appropriate applications. For example, we assist clients that produce or export:

  • Computers for Analog-to-Digital Conversion
  • Computers for Signal Processing or Image Enhancement
  • Computer Operating Systems
  • Computers Performing Information Security Functions
  • Electronic Assemblies
  • High Performance Computers
  • Hybrid Computers
  • Neural Computers
  • Optical Computers
  • Systolic Array Computers


Computing items containing encryption deserve special attention as the Bureau of Industry and Security separately regulates encryption technologies in Category 5, Part 2. Our attorneys have extensive experience with obtaining licenses and locating license exceptions for items with encryption features.

Recent Matters:

  • Advised computer and software companies in enforcement matters involving exports to China before the Commerce Department’s Bureau of Industry and Security

For more information, please contact Roz Thomsen.