As of September 11, 2009, BIS published advisory of downloading of encrypted software reviewed and classified as mass market, to be downloaded free of charge to anyone from the company's website without restriction.
The advisory mention it would not be in violation of EAR if it posts mass market encryption software on the Internet for free and anonymous download and then at a later time the software is downloaded by an anonymous person in embargo countries such as Iran, Cuba, Syria, Sudan or North Korea.
The BIS advisory don't mention any company's name for this case determination.
It may be some relation with the case is for Mozilla Firefox open source project below.
During a recent Firefox download event, Mozilla posted a map on its Web site showing where downloads were occurring. It became clear that a substantial number of downloads were coming from Iran. Mozilla then had knowledge that it was exporting to Iran, which could have put it in violation of the U.S export regulations, exposing the firm to criminal and financial penalties. At that point, Mozilla made a voluntary disclosure to federal authorities in the hopes of securing a no-violation letter.