I have been trying to figure this out as well. I am just guessing as I haven't found anything specific, but since this is being issued by the department of comm

I have been trying to figure this out as well. I am just guessing as I haven't found anything specific, but since this is being issued by the department of commerce, I would assume that downloading an app from the Google Play or App Store would constitute a transaction, even if the price of the software is free, and the government can order that these are products that constitute a national security risk.