Case No. IA-11074

Date issued: Apr. 29 2009

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TURBOFAC Commentary (194 words)

Notes:

1) This application of the publishing GL appears to confirm that “add[ing] commentaries in English” to pre-existing would have, even prior to the 2016 Publishing Guidance, constituted the “substantive alteration” of pre-existing materials that would have been outside the scope of the informational materials exemption. This is no surprise. What is useful about the guidance is the confirmation that the exportation or other sale of materials for which the publishing GL is necessary for the creation is, itself, exempt from regulation (once the substantive alterations requiring the publishing GL are complete).

2) The guidance is also notable for the confirmation that U.S. persons may employ Iranians as consultants in connection with the translation and commentaries on pre-existing informational materials. The publishing GL explicitly references “[p]ayment of royalties for written publications” as authorized, as well as “[c]ollaborating...