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Zimmermann challenged these regulations in a curious way.
He published the entire source code of PGP in a hardback book, via MIT Press, which was distributed and sold widely.
Anybody wishing to build their own copy of PGP could buy the $ 60 book, cut off the covers, separate the pages, and scan them using an OCR program, creating a set of source code text files.
One could then build the application using the freely available GNU Compiler Collection.
PGP would thus be available anywhere in the world.
The claimed principle was simple: export of munitions — guns, bombs, planes, and software — was ( and remains ) restricted ; but the export of books is protected by the First Amendment.
The question was never tested in court with respect to PGP.
In cases addressing other encryption software, however, two federal appeals courts have established the rule that cryptographic software source code is speech protected by the First Amendment ( the Ninth Circuit Court of Appeals in the Bernstein case and the Sixth Circuit Court of Appeals in the Junger case ).

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