Case No. IA-17201-1

Date issued: Feb. 28 2014

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TURBOFAC Commentary (751 words)

Notes:

1) BACKGROUND

The applicant here (Nokia) asks to provide a “mapping software product, Ovi/Nokia Maps, and related services from the United States to Iran.” Based on publicly available information released contemporaneous with the application (see e.g. https://www.youtube.com/watch?v=rmOz1iVypnE), it is clear that Ovi/Nokia Maps is similar to google maps in the sense that it does, or can, involve the downloading of a software app, and that software app will display maps (which may be pre-loaded or transmitted over the internet) and allow the user to generate directions from place to place on the map (i.e. GPS-based navigation tools).

As discussed at length in Notes Common to the "Information or informational materials" Definitional Provision, the relationship between the informational materials exemption and “software” is unclear as it relates to the exportation of software in object code. In this case, OFAC...