Registering LabVIEW code in China

[Thomas_robertson]

We are trying to register our LabVIEW code in China.  

There are very specific requirements to do that, including printouts of code (the first and last continuous 30 pages) with specific line spacing formats.

Obviously this is a problem for LabVIEW code.  Has anyone else been through this before or have some idea who to ask about the implications of the Chinese requirements for LabVIEW programmers?

[Dennis_Knutson]

Can you explain where you found these requirements? Is this code you are trying to sell or something else?

[Thomas_robertson]

This is a commercial software product which we sell (in compiled format).

From our lawyers:

There are some slightly odd regulations about how software copyright must be recorded. Here is the requirement in full:

“If the source code is fewer than 60 pages, the entire source code shall be provided. The source code should be printed on A4 sized paper, the lines on each page of the source code should not be fewer than 50.  The name and version number of the software need to be written at the page header of the source code and the page number should be marked at the top right corner of the source code. 

If there are >60 pages, then you have the option to provide 

i)     the first continuous 30 pages and last continuous 30 pages of the source code, covering any confidential part wide black diagonal, but the covered part shall not exceed 50% of the submitted source code; or

ii)    the first continuous 10 pages and any continuous 50 pages of the source code; or

iii)  the first and last continuous 30 pages of the object code and any continuous 20 pages of the source code.”

Basically we need to ensure that what is copied appears in your recordal. I am not sure how NI LabView software like SoundCheck is distributed, but I presume it’s a normal self-contained, compiled object file – and I presume that the code would run to more than 60 pages. So ideally I would suggest option (iii), where we submit the first and last continuous 30 pages of object code – hopefully containing the compiled code for some of your <edited> – plus a dull 20 pages of source code, perhaps that relating to the user interface. But I have made some assumptions about the file structure there – it would help if someone more familiar could comment – maybe you have considered similar issues in the US?

[Dennis_Knutson]

Sorry, I thought you might be doing something else. I've distributed code to China (to a contract manufacturer) but never applied for copyright protection.

[Thomas_robertson]

Do you think I should I call NI support?

[Dennis_Knutson]

Don't know if they are able to help with your copyright issues.

[Hooovahh]

Yeah I'd talk to NI.  My first impression is to say that you have zero lines of code, but printed takes more than 60 pages.  There are ways to programatically document your code.

It can take a VI and bascially make screenshots for all code, as well as all states of all case structures.  As you can imagine this balloons to a huge size very quickly if you have many sub VIs with many state machines.

Not to wear the sales hat or anything but we actually have a product that can document VIs like this and make them into HTML pages, or compiled CHM help files.

Documentation Generator

[Pcorcs]

The best contact regarding legal questions with export materials can be found here:

http://www.ni.com/legal/export-compliance.htm

Thank You,

[Thomas_robertson]

My boss suggested that perhaps similar issues come up with G code and meeting FDA requirements.  

Essentially, he suggested that perhaps there are methods for printing out and documenting code used in FDA compliance that may be applicable to us.

Anyone have an insight there?

[Thomas_robertson]

Well, we heard back that the Chineese authorities will not accept graphical code for registration in China.  It has to be textual, and they will not accept object code either.  So I think we're at a dead end unless we want to lobby to change China's copyright laws. 

To my knowledge there is no way to turn LabVIEW code into a textual representation.  It's either G or it's machine code.  I'm right about that, correct?

Any of you NI guys have any smart ideas?  

From our lawyer: "I checked with our team in China and the Copyright Administration will not accept LabVIEW’s graphical source code. Short sighted in my view as LabVIEW is far from being the only visual programming language, but that is the position. We do need the source to record as well, just object code alone is not adequate."