in070182


From: David A. Wheeler [dwheeler@dwheeler.com]
Sent: Wednesday, January 24, 2007 2:17 PM
To: Rajchel, Lisa; Garner, Jennifer; Desautels, Sara; Scully, Henrietta


Subject:   David Wheeler 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



Dear Lisa Rajchel, Jennifer T. Garner, Sara Desautels, and Henrietta Scully:

I am sending this email to you because your organisation is a liaison member of ISO JTC1 (International Standards Organisation Joint Technical Committee 1).

Please vote AGAINST permitting Ecma 376 (Ecma Office Open XML File Formats) to proceed on the ISO standards fast track through the ISO JTC-1 committee.  Instead, please instruct Ecma to (1) develop general-purpose extensions to the international standard  (ISO/IEC 26300:2006 aka OpenDocument) instead if needed, and (2) ensure that legal rights are granted so all suppliers (proprietary and open source software, using all of their most common license practices) can implement the extensions (including all later revisions of it).

Ecma 376 is a duplicative standard of an existing standard that is already implemented by multiple vendors.  But worse, it is in essence a "vendor lock-in" standard, essentially implementable by only a single company (Microsoft).  The world does not need to have document processing permanently controlled by a single company via a single-company specification.  When OpenDocument's development was completed, and submitted to ISO, Microsoft began this process with Ecma to create a "competing" standard whose primary purpose appears to be ensuring that products will never be able to compete with Microsoft Office on their merits.  I urge you to reject this gaming of the standard-setting process.

Problems with Ecma 376 include the following:
* Ecma 376 contradicts numerous international standards.  This is most obvious when considering ISO/IEC 26300:2006 (OpenDocument), a standard already implemented by multiple vendors, for EXACTLY the same purpose as Ecma 376.  But it also contradicts with other standards including the Gregorian calendar, ISO 8601 (dates/times), ISO 639 (languages),  W3C SVG (Scalable Vector Graphics), W3C MathML (Mathematical Markup Language), and W3C SMIL (Synchronized Multimedia Integration Language).
* Ecma 376 cannot be reasonably implemented by other vendors. It relies on undisclosed information (e.g., requires that behavior of proprietary applications be cloned without disclosing that behavior), and lawyers who have examined the "rights" granted by Microsoft believe that in fact there are inadequate rights granted for competitors to safely use this specification.
* Ecma 376 is immature and inconsistent.  It has numerous internal inconsistencies (such as those involving w:sz and ST_Border), poor names and inconsistent naming, an inflexible notation for percentages,  an inflexible numbering format, and uses a Microsoft-specific namespace.  Its use of bitmasks inhibits extensibility and use of standard XML tools.
*Ecma 376's full name, "Office Open XML", confuses the marketplace.  This is the original name of OpenDocument, and is excessively similar to a competitor's product (OpenOffice.org).

There is no market need for Ecma 376.  Almost no documents today are exchanged using Ecma 376.  There is a vast sea of documents in the older doc/ppt/xls formats, but these binary formats are not what is being proposed or even revealed.

A much lengthier description of problems is given here: http://www.grokdoc.net/index.php/EOOXML_objections

Given all of the concerns about this issue, it seems prudent to AT LEAST remove it from fast-track status.  I have every confidence that if more time is spent examining the issues surrounding this specification, it will be rejected and eventually replaced with a more suitable and inclusive specification.

Thank you for your time.

--- David A. Wheeler
Software developer, document writer, and citizen of the United States of America