Dropbox, Inc. (2018 Correspondence With the SEC)

Date issued: Feb. 02 2018

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TURBOFAC Commentary (844 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 Dropbox business would not be more clearly authorized by GL D, since the GL is no longer limited to "personal" communications”. This item is still notable as it relates to interpretations of GLs that are still limited on their faces to "personal communications"-related software and services.

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1) The text reproduced here comes from two letter exchanges between Dropbox, Inc. and the SEC in the runup to Dropbox’s 2018 IPO. Dropbox is an internet service provider whose primary offerings consist of cloud storage, file...