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Subject: Contribution regarding functionally equivalent naming conventions and the new compliance model

Dear LegalDocML members,

I would like to submit the following comments to the latest proposal of changes with regard to the functionally equivalent naming conventions and the new compliance model and the related presentation attached to this mail for ease of reading.

These comments generate from the Publication Office of the European Union which analysed the latest proposal and exchanged with me on the subject.

Given the short notice and the urgency of this communication, we did not pay too much attention to the formulation of the comments which sometimes may seem very direct and synthetic.



PPT, page 3 and page 6 (point 7b):

FRBRportion shall remain optional, because someone may choose NOT to split a document in several XML instances.


PPT, pages 4-5:

As these requirements are subjective and therefore hard to measure and evaluate, we suggest that they are treated as guidelines.


PPT, pages 6:

Concerning requirements 5 and 6, we suggest removing them. The fact that one has to provide a resolver and a converter goes against the principle of having all naming conventions on an equal footing.


PPT, page 9:

"This chapter defines Akoma Ntoso conformance clauses. Akoma Ntoso specifications MUST be valid against the XSD schemas included in the zip file under the Annex B. The zip file includes:"


We understand that instead of "specifications", it should read "instances".


PPT, page 13:

The new compliance levels need to become clearer and further supported by examples. Moreover, we need to have a definition of the concepts (Basic metadata, Normative references, Advanced metadata, Semantic elements), so that one can safely determine against which level AKN documents are compliant.

Finally, we need to have one compliance level corresponding to simple conformance as it is defined in the conformance clause under: http://docs.oasis-open.org/legaldocml/akn-core/v1.0/csprd02/part2-specs/materials/akn-core-v1.0-csd02-part2-specs-3.html


Thanks for considering these points as contribution to the LegalDocML standardization process






Gianluigi ALARI

ICT applications specialist


European Parliament

Directorate-General for Innovation and Technological Support

Directorate for Development and Support


Project Management

LUX – SCH 06A003 - Tel. +352 4300 25938





--- Begin Message ---
Dear LegalDocML members,

in the light to find a cooperative and reasonable solution to the requests of some stakeholders (e.g., ELI group) concerning the possibility to accept "functionally equivalent naming conventions" (FENC), we are proposing a new definition and a rewording of the conformance rules. Additionally a new grid for the "levels" of compliant is proposed (e.g. bidimensional matrix).

The proposal recognise the following solutions equally eligible for the AKN level 2:

  • AKN naming convention OR
  • FENC and FRBRAlias using AKN naming convention OR
  • FENC and full FRBR metadata.

It includes the possibility to reuse existing metadata coming from other standards (e.g., national ELI ontology) for populating FRBR metadata, and in this manner to annotate the minimal dataset necessary for guaranteeing the interoperability between AKN naming convention and FENC.

We want to discuss this proposal in the next LegalDocML TC meeting scheduled at 31st August, 18.30 CEST time.
It is extremely important to reach a large participation in the next TC meeting, for making the discussion fruitful.
The intention is to formulate the final answer to the public review comments and the associated new documentation for the F2F meeting in Ravenna in order to speed the process of standardization.

Best regards,
Monica and Fabio

Associate professor of Legal Informatics 
School of Law
Alma Mater Studiorum Università di Bologna 
C.I.R.S.F.I.D. http://www.cirsfid.unibo.it/ 
Palazzo Dal Monte Gaudenzi - Via Galliera, 3 
I - 40121 BOLOGNA (ITALY) 
Tel +39 051 277217 
Fax +39 051 260782 
E-mail  monica.palmirani@unibo.it 

Attachment: Akoma NtosoNamingConvention - functionally-equivalent.pptx
Description: Akoma NtosoNamingConvention - functionally-equivalent.pptx

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