in070197



From: Karl O. Pinc [kop@meme.com]
Sent: Monday, January 29, 2007 12:54 PM
To: Garner, Jennifer
Cc: bryden@iso.org; ISOTeam-ANSI


Subject:    Karl Pinc Contribution on Behalf of The Meme Factory, Inc. 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




Jan 29, 2007

Karl O. Pinc
President,The Meme Factory, Inc.
5755 South Harper
Chicago, IL 60637
kop@meme.com

InterNational Committee for Information Technology Standards Jennifer Garner Associate Director, Standards Programs jgarner@itic.org

Dear Sirs and Madams,

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)  As an individual who owns and operates an IT business, I am very concerned about the possibility of this standard receiving ISOapproval.

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 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.

Very truly yours,

Karl O. Pinc
President, The Meme Factory, Inc.
<kop@meme.com>

cc: Mr. Alan Bryden
     ISO Secretary General
     bryden@iso.org

cc: American National Standards Institute
     isot@ansi.org

cc: Nancy George
     President, Software Quality Management, Inc.
     ACM Voting Member ISO JTC1
     info@sqminc.com