Ryan:
You ask a good question. The Export Administration Regulations (EAR)
provide a rather broad definition of what constitutes "cryptographic"
software. And then they make a number of exceptions.
It is unclear whether or not DESCHALL fits the broad definition. But
it does not appear to fit any of the exceptions.
If you (or a lawyer-type-person) would like to ask the Commerce Department
for a ruling, we can find out the definitive answer to the question.
Otherwise, anyone who exports the software will have to have a lot
more faith in the US Government's sense of "reasonableness" than I do.
I have said many times, "The only restriction on the redistribution
of the DESCHALL clients are those imposed by the US and/or Canadian
governments."
If you are certain that the US Government is not imposing any
restrictions, then it's a matter between you and your US Attorney. :)
Cheers!
-- Rocke