Do you or we need to obtain a permit to export our product integrated with Orion?

Provided you limit the use of Orion for its intended purpose (ie., for license management) and you do not use Orion’s extensibility capabilities as a conduit for storage of your own encrypted user-level data, you are not required to obtain an export permit merely by virtue of integrating your product with Orion.

The encryption software used by Orion is not subject to export control laws per U.S. Department of Commerce Bureau of Industry and Security’s Export Administration Regulations publication “Commerce Control List Category 5 – Information Security” published March 5, 2003. Per the applicable ECCN 5D992, Orion is exempt because of its use of encryption exclusively for the purpose of software copy protection. A license is currently required for export to Sudan, Syria and North Korea, and special steps are required for export to Cuba, Iraq and Rwanda. This list may change over time. There are no restrictions, licenses or special procedures required for you to export Agilis’s products to any other country. For further details, please see http://www.access.gpo.gov/bis/ear/ear_data.html and also see the complete description of export regulations at http://www.bis.doc.gov.