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Subject: ODF 1.2cd01 --- AWOL interoperability conformity requirements
Committee Draft 1 includes 3, 449 occurrences of MAY, 20 occurrences of MAY NOT, 5 occurrences of NEED NOT, and 28 occurrences of OPTIONAL, used almost exclusively to express options. This total of 3,502 occurrences of terms indicative of options is as opposed to only 272 occurrences of requirement keyword terms indicative of mandatory requirements. This condition does not measure up to governing requirements. Under ISO/IEC JTC 1 Directives, (5th Ed., v. 3.0, 5 April 2007), Annex I, pg. 145, <http://www.jtc1sc34.org/repository/0856rev.pdf>: "Standards designed to facilitate interoperability need to specify clearly and unambiguously the conformity requirements that are essential to achieve the interoperability. Complexity and the number of options should be kept to a minimum[.]" At ibid, pg. 11, those requirements are made mandatory for all JTC 1 standards absent the consent of the Secretaries-General of ISO and IEC. See also Agreement on Technical Barriers to Trade article 2 section 2.2, <http://www.wto.org/english/docs_e/legal_e/17-tbt_e.htm#articleII>: "Members shall ensure that technical regulations are not prepared, adopted or applied with a view to or with the effect of creating unnecessary obstacles to international trade. ..." See also ibid. section 2.6 (preparation of international standards is one method of preparing "technical regulations"). The Agreement thus raises the issue of whether interoperability barriers created by international standards are "unnecessary obstacles to international trade." In my studied opinion, the JTC 1 Directives interoperability requirements should be understood as the ISO/IEC translation of the Agreement provision quoted above into the IT international standard context. See e.g., World Trade Organization Committee on Technical Barriers to Trade, Decisions and Recommendations Adopted by the Committee Since 1 January 1995 (May 23, 2002), pg. 28, <http://docsonline.wto.org/imrd/directdoc.asp?DDFDocuments/t/G/TBT/1R8.doc> (international standards "should not distort the global market, have adverse effects on fair competition, or stifle innovation and technological development"). In the IT specifications sector, full specification of interoperability conformity requirements is fundamental to fair competition among implementers. See e.g., Commission v. Microsoft, European Community Court of First Instance (Grand Chamber Judgment of 17 September, 2007), para. 226, 230, 421, http://curia.europa.eu/jurisp/cgi-bin/gettext.pl?where=&lang=en&num=79929082T19040201&doc=T&ouvert=T&seance=ARRET (rejecting Microsoft's argument that "interoperability" has a 1-way rather than 2-way meaning; information technology specifications must be disclosed with sufficient specificity to place competitors on an "equal footing" in regard to interoperability; "the 12th recital to Directive 91/250 defines interoperability as 'the ability to exchange information and mutually to use the information which has been exchanged'"). OASIS ODF v. 1.0 section 1.2 incorporated by reference the RFC 2119 requirement keyword definitions that bounded each occurrence of the terms MAY and OPTIONAL with two mandatory interoperability requirements: "5. MAY -- This word, or the adjective "OPTIONAL", mean that an item is truly optional. One vendor may choose to include the item because a particular marketplace requires it or because the vendor feels that it enhances the product while another vendor may omit the same item. "An implementation which does not include a particular option MUST be prepared to interoperate with another implementation which does include the option, though perhaps with reduced functionality. "In the same vein an implementation which does include a particular option MUST be prepared to interoperate with another implementation which does not include the option (except, of course, for the feature the option provides.)" RFC 2119, <http://www.ietf.org/rfc/rfc2119.txt> (broken into separate paragraphs for legibility). The result was that in OASIS ODF 1.0 --- counting each option as including two mandatory requirements --- the specification had 4,505 occurrences of terms indicative of options whilst having 7,415 occurrences of terms indicative of mandatory requirements. However, at JTC 1, British Standards Institute included the following comment on DIS ISO/IEC:26300 along with its ballot: "The text does not conform to Annex H of the ISO Directives defining acceptable verbal forms for the expression of provisions (i.e. the use of "shall", "should", etc.). It uses the conventions of IETF RFC 2119 instead. Our understanding is that the PAS procedure does not allow exemption from this requirement." BSI recommended: "Edit all provisions to conform to Annex H of the ISO Directives." See BSI comments in zipped attachment to ISO/IEC JTC 1/SC 34N0728rev, Summary of Voting on DIS ISO/IEC 26300 - Open Document Format for Office Applications (OpenDocument) v1.0 (13 June 2006), pg. 1, <http://www.open-std.org/JTC1/sc34old/repository/0728revc.htm>. Unfortunately, BSI's "all provisions" phrase was ignored and only section 1.2 was modified, dropping the incorporation by reference of RFC 2119 and substituting in its stead a reference to ISO/IEC DIrectives Part 2 Annex H definitions. ISO/IEC:26300-2006 was left liberally strewn with undefined requirement keywords. More importantly, no editing occurred to restore the up to 7,192 instances of mandatory interoperability requirements snuffed out of existence by the flip in the requirement keyword definitions. Under ISO/IEC Directives Part 2 Annex H definitions, OPTIONAL is undefined and MAY takes its common and ordinary meaning of "permission," unbounded by mandatory interoperability requirements. While the Editors have made progress in Committee Draft 1 in replacing the occurrences of OPTIONAL with MAY, there appears to be no progress at all on restoring mandatory interoperability requirements phrased in ISO/IEC Directives Part 2 terminology. See Committee Draft 1 statistics above. The "conformity requirements essential to achieve the interoperability" made mandatory by JTC 1 Directives remain unspecified. Indeed, the situation calls into question whether DIS ISO/IEC:26300 (OASIS ODF 1.0) or ISO/IEC:26300-2006 is the existing international standard. OASIS ODF 1.0 was adopted as an international standard without dissenting ballot. Although a ballot resolution meeting was scheduled, it was canceled because of the lack of dissenting votes and the final changes including those under discussion were approved by ITTF rather than by NB ballot. See Alex Brown, The Maintenance of ODF – an Aide-mémoire, Where Is There an End of It? (6 November 2008), <http://www.adjb.net/post/The-Maintenance-of-ODF-e28093-an-Aide-memoire.aspx>. A very similar issue arose in the processing of DIS ISO/IEC:29500 OOXML when India appealed the decision to adopt that specification as an international standard, arguing that because the specification resulting from the changes agreed to at the specification's ballot resolution meeting was not published by the close of the balloting period. The ISO Technical Management Board recommended rejection of the appeal on that basis, stating: "6. 'Final' text of ISO/IEC 29500 or ISO/IEC DIS 29500, or 'revised FDIS text', not released "6e. Correct but irrelevant. The decision being appealed is the JTC 1 decision to approve the draft. The text mentioned in the Directives and by the appellants is not germane to that decision, *which must be taken on the basis of the original DIS text and the actions taken by the BRM on the comments.* The provision of any revised text is not for purposes of further decision by NBs." ISO Technical Management Board Secretariat, Appeals on ISO/IEC DIS 29500 Open Office XML, No. 078/2008 (4 July 2008), pg. 5, <http://www.groklaw.net/pdf/ISOAppealRecommendationTMB.pdf>; see also India appeal at ibid., pp. 13-14. In the case of DIS ISO/IEC:26300 ODF, it was adopted as an international standard without dissenting ballot and there was no BRM convened for the NBs to act on any comments received along with ballots. The NBs and not ITTF have the authority to adopt alterations to DIS specifications as was recognized by the ISO TMB in the DIS ISO/IEC:29500 case. ITTF therefore appears to have acted outside its authority and in disregard of JTC 1 Directives interoperability requirements in approving the wholesale abandonment of mandatory interoperability requirements contained in DIS ISO/IEC:26300, without the approval of NBs and without the required consent of the Secretaries-General of ISO and IEC. Recommendation: Issues such as those discussed above should be mooted by fully specifying the interoperability conformity requirements --- including implementation behavior --- essential to achieve the interoperability, with particular attention paid to existing options. Per JTC 1 Directives, the number of options should be minimized and the degree of complexity in the specification should be drastically reduced through reduction of options. OASIS ODF 1.0 relied far too heavily on the RFC 2119 definition of MAY and OPTIONAL, requiring interoperability despite options without specifying the methodology for achieving that state such as identification and preservation of relevant markup. Such deficiencies need to be rectified in ODF 1.2. Doing so should not be unduly difficult. E.g., the mass of options in the specification mask hard-coded SHALL and SHALL NOT programming decisions in the market leading implementations. Disclosure of those programming decisions and translation into SHALL and SHALL not provisions in the specification would considerably advance toward completion of the interoperability editing task. Best regards, Paul E. Merrell, J.D. (Marbux) -- Universal Interoperability Council <http:www.universal-interop-council.org>
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