a.4.  Carbon dioxide (CO2)"lasers" having any of the following:

   a.4.a.  A CW output power exceeding 15kW;

          a.4.b.  A pulsed output having a "pulse duration" 
                  exceeding 10 ns and having any of the following:

               a.4.b.1.  An average output power
                         exceeding 10 kW; or

               a.4.b.2.  A pulsed "peak power"
                         exceeding 100 kW; or

          a.4.c.  A pulsed output having a "pulse duration" 
                  equal to or less than 10 ns; and having
                  any of the following:

               a.4.c.1.  A pulse energy exceeding 5J per pulse; or

               a.4.c.2.  An average output power
                         exceeding 2.5 kW;



License Exceptions

     (c) Pulsed carbon dioxide "lasers" controlled
         by 6A005.a.4.c (except industrial CO2 lasers used
         in applications such as cutting and welding)
         having all of the following characteristics:
          (1) Operating at wavelengths between
              9,000 and 11,000 nm;
          (2) A repetition rate > 250 Hz;
          (3) An average output power > 500 W; and
          (4) A pulse width < 200 ns;


We can see from the above ECCN text that this information relates to a pulsed laser and not
the 17kW CW and so, does not apply.


CO2 "lasers"
               controlled by 6A005.a.4 that operate
               in CW multiple-transverse mode; and
               having a CW output power not
               exceeding 15 kW; 

Clearly, this section does apply to our laser.  The highlighted words are the attributes 
which are controlled.  We only need to show the attributes that are controlled.  
Our intitial description has all of the important information, but we should arrange it 
in order of importance;  "multimode CW CO2 laser of 17kW"  becomes a technical specification of: 
"17kW CW multimode"  It is not necessary to call it a laser again because it already got an ECCN 
that tells us that, as well as a product name of CO2 laser 

Yes, for 6A005.d (except d.2.c), CO2
            or CO/CO2 "lasers" having an output
               wavelength in the range from 9,000
               to 11,000 nm and having a pulsed
               output not exceeding 2 J per pulse
               and a maximum rated average single
               or multimode output power not
               exceeding 5 kW;

"6A995  "Lasers", not controlled by 6A005 or 6A205.

states:

a. Carbon dioxide (CO2) "lasers" having any of the
following:

     a.1.  A CW output power exceeding 10 kW;

     a.2.  A pulsed output with a "pulse duration"
           exceeding 10 microseconds; and

          a.2.a. An average output power exceeding 10 kW; or

          a.2.b.  A pulsed "peak power" exceeding 100 kW; or

     a.3.  A pulsed output with a "pulse duration"
           equal to or less than 10 microseconds; and

          a.3.a.  A pulse energy exceeding 5 J per
                  pulse and "peak power" exceeding 2.5 kW; or

          a.3.b. An average output power exceeding 2.5 kW;

provides us with a 10kW limit on these same lasers. The information for both lasers would be 
best consistantly shown in the order "12kW CW multimode".  

All CW lasers would have their type as the product and power as a technical spec.  
If it were a pulsed laser the pulsed power would be given.  If a laser were wavelength tunable
that spec would be shown if it were part of the controlling specifications.  If there were 
hundreds of lasers with similar specifications they could be grouped into those >10kW & <15kW,
>15kW & <20kW,m and so on.