Iran General License (No. D-2) - General License with Respect to Certain Services, Software, and Hardware Incident to Communications

Date issued: Sep. 23 2022

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TURBOFAC Commentary (6568 words)

Notes

 

0.1) 9-23-22 UPDATE TO GL D

 

0.2) THE DIFFERENCES BETWEEN GL D-1 AND GL D-2; IMPACT ON INTERPRETATION OF OTHER COMMUNICATIONS-RELATED GLs

  (a)  In General

  (b)  Changes from GL D-1 to GL D-2 and Related Interpretive Issues

     (i) “No-Cost” Services Now Included, Rendering 560.540 Functionally Obsolete

     (ii) The Change From “Personal Communications” to “Communications” – the “Cloud-Based Services and Software” GL and Implications for the Meaning of “Personal Communications” in Other GLs

     (iii) With Respect to Software, the Change From “Necessary to Enable Services Incident to the Exchange of Personal Communications” to Software “That Is Incident to, or Enables Services Incident to, the Exchange of Communications Over the Internet”

     (iv) Change in the “Internet Connectivity” GL From “Consumer Grade” to “Non-commercial Grade”

     (v) “Web-Hosting Services” and Domain Name Registration Authorized (to an Extent); Relationship with