Well you are correct, mIRC itself could be exported no problem. The problem lies in that Windows itself doesn't have SSL functions (well it does, but they are horribly horribly horribly written, and horribly difficult to use), so therefore most likely mIRC would have to include another SSL library, such as OpenSSL. OpenSSL does fall under the export restrictions. So the only way around it would be you download mIRC from mirc.com then when you install it, if you place ssleay.dll and crypto.dll in the mIRC directory, mIRC now supports SSL (you'd get these files from the OpenSSL website). If mIRC were to distribute the dlls along with mIRC, then it would fall under the export restrictions.