Earlier quoted context omitted.
It's whatever they mean by that word here: http://www.bis.doc.gov/index.php/policy-guidance/encryption/... If you're not sure, and don't want to risk it, either do the ERN or get a lawyer to tell you it's not needed.
I'm not disagreeing with you, I'm pointing out that querying a RESTful page with any of the C, R or U parts of the CRUD process would involve transacting information, so you basically need to keep it as HTTP. And that's why it's madness.
It's quite simple to implement an instant messaging app on top of CRUD, so "it's just CRUD" is not a valid counter against this type of politics.