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The Constitution states, 'no Bill of Attainder or ex post facto Law shall be passed'; to the extent that those executive agencies' enabling legislation permits ex post facto regulations, that legislation is unconstitutional.


The Government can simply ban the use of that software without a license set at a future date (i.e. 1/1/2017).

New Regulation -> Future Date -> Ex post facto claims don't happen.

That is the process my original comment intended to imply.




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