Response: BIS agrees. The phrase "not otherwise enumerated in this ECCN" . . ." does not appear in ECCN 3E611.a of this proposed rule.
Comment: One commenter noted that paragraph .b of ECCN 3E611 in the
Response: BIS agrees that the technology in ECCN 3E611.b should not apply beyond helix traveling wave tubes, transmit/receive modules, MMICs and discrete microwave transistors covered by ECCN 3A611, and this proposed rule modifies ECCN 3E611.b to that effect. This proposed rule does not adopt the commenter's suggestion to eliminate paragraph .b. Paragraph .b is needed because use of License Exception STA is limited to "build-to-print" technology with respect to the items listed in paragraph .b. No such limitation applies to paragraph .a.
Comment: One commenter noted that proposed ECCN 3E611 applied to " `technology' `required' for the `development,' `production,' operation, installation, maintenance, repair, or overhaul of . . . ." and proposed replacing that phrase with the phrase " `technology' `required' for the `development,' `production,' operation, installation, maintenance, repair, and overhaul of . . ." or with the word "use." The commenter noted that its recommended change would make ECCN 3E611 consistent with other technology ECCNs in which the word use indicates that the software must perform all six functions to be covered.
Response: BIS is not making this change. As described above, BIS is revising 3E611 to include all six elements.
Comment: One commenter noted BIS's
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