You didn't geobock the download or prompt for then user's address first in your scenario. So it may constitute export because it would be reasonable to assume that you clearly intended to make it available worldwide.
Phil Zimmerman was investigated for illegaly exporting munitions because he made PGP available via FTP. The case was settled, so I don't know whether this argument would ultimately have been successful.
alt Hacker News
I am not a lawyer. Still, my two cents are:
You didn't geobock the download or prompt for then user's address first in your scenario. So it may constitute export because it would be reasonable to assume that you clearly intended to make it available worldwide.
Phil Zimmerman was investigated for illegaly exporting munitions because he made PGP available via FTP. The case was settled, so I don't know whether this argument would ultimately have been successful.