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  1. As everyone knows, section 889 of the 2019 NDAA prohibited the use of telecommunications equipment made by Huawei, ZTE, and others. It was implemented in the FAR in August and December 2019 with two certifications and a clause. My question is this: what is 'telecommunications equipment'? It was not defined in the NDAA, nor in the certifications or the clause. There is no definition anywhere else in the FAR. The term is used in Part 39, but it is not defined. The closest the FAR comes to a definition is in the list of exceptions, which states that equipment "that cannot route or redirect user data traffic or permit visibility into any user data or packets that such equipment transmits or otherwise handles" is excepted. I guess we can infer that if the equipment does do that, it is the covered equipment. Do we have anything better than that?