Cloudflare, Inc. (2019 Correspondence With the SEC)

Date issued: Jun. 28 2019

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TURBOFAC Commentary (272 words)

Notes:

* On 9-23-22, OFAC replaced Iran GL D-1 with Iran GL D-2. See Iran GL D-2, and comments thereto, for a discussion on the changes between GL D-1 and GL D-2. The comment below has not been amended as a result of the issuance of GL D-2, but note that the addition of "user authentication" to GL D-2 may make it clearer than it was before that Cloudflare's services are authorized for export to Iran.

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1) Cloudflare, which provides internet security-related services such as DNS, SSL certificates and mitigation of DDoS attacks (i.e. a firewall), considers its "Global Cloud Platform" (https://www.cloudflare.com/plans) to be generally licensed for non-fee Syrian and Iran users through both the GLs for “services incident to [] exchange of personal communications” (560.540 and...