in070131




From: Felix Oxley [felix.oxley@gmail.com]
Sent: Monday, January 22, 2007 4:54 PM
To: Garner, Jennifer; rajchel@ansi.org; Desautels, Sara


Subject: Felix Oxley Contribution in Response to JTC 1 N 8455 - 30 Day Review for Fast Track Ballot ECMA-376 | ISO/IEC DIS 29500 Office Open XML File Formats

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Dear Sir or Madam,

Earlier this month ECMA International submitted a standard for "fast-track" ISO approval. That is the "Ecma 376 Office Open XML"
standard. (ISO/IEC DIS 29500)

Ecma-376 is a standard for "word-processing documents, presentations, and spreadsheets" which overlaps completely with an existing, approved standard ISO/IEC 26300:2006 (OpenDocument (ODF)). Therefore it conflicts directly with ISO's goal of having one standard for any area.

Furthermore, this specification is so complex (>6,000 pages) and vendor-specific that it can only be successfully implemented by Microsoft Office (the application on which it is modelled).

Ecma 376 also violates section 2.14 of the ISO/IEC Directives, Part 1, in that not all of what it takes to implement the standard is covered by the licensing conditions offered by Microsoft.

The numerous concerns over Ecma 376, as pertaining to ISO approval, are summarized on this page:
http://www.grokdoc.net/index.php/EOOXML_objections.
The page lists many contradictions in Ecma 376 as defined by the ISO rules.

The initial review period ends in two weeks, on February 5th. If none of the "P-Members" of the ISO/IEC JTC1 (Joint Technical Commitee 1) raise a "contradiction", the specification will go through the "fast-track" process towards ISO approval.

I believe, and I hope that you will agree, that this standard should not be allowed "fast-track" approval.
Rather it should be remanded to Ecma International for: (i) harmonization with ISO/IEC 26300:2006 and numerous other standards and
(ii) development of more suitable intellectual property documents.

Yours truly,
Felix Oxley