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Massachusetts Lowers its Standards - Updated 3Xs
Tuesday, July 03 2007 @ 01:55 AM EDT

Massachusetts has added Ecma-376 Office OpenXML to the list of potentially acceptable "open formats". Folks are writing headlines like Massachusetts Kowtows to Microsoft. [More reactions.]

But it is worse than that. From my reading, they've lowered the bar for choosing what standards to use, rather than requiring Microsoft to rise to the open formats/open standards level the state originally set.

They are asking for comments, because they have to, I guess, but I doubt they care what you tell them. The cutoff to comment is July 20, if you wish to. It looks to my simple eye like the fix is in. But cynicism doesn't accomplish much, so if you wish to comment, here's my suggestion.

I'd use this chart entitled "Decision Process for Recommending a Standard/Specification as an Enterprise Standard" as a good stepping off point -- scroll all the way down the page -- because I don't see how in the world OpenXML can make it through that chart. It stumbles on the very first rung. According to Massachusetts' own criteria, it has to be able to say yes to this question:

Is the standard fully documented and publicly available?

Fully documented? Open XML? Sir, you jest. If it were, Microsoft wouldn't need to make Novell and Xandros and Linspire sign NDAs and then write translators for them, now, would they?

Translators that Steve Ballmer already told us won't work perfectly. Why not? If you read Rob Weir's explanation of the difference between representation and specification, you'll find out that what Open XML is full of is representations that mean something to Microsoft but not to us outsiders:

So what is the difference between representing and specifying? When you represent, it means that you can map from the features of the legacy format to the the new format. When you specify, it means that you provide the map, and enough detail so that others can read and write that same representation. That is a big difference.

Of course, OOXML is more than 1's and 0's. But when you see attributes with names like, "useWord97LineBreakRules," with no additional specification, then you know that the fix is in.

My sentiments exactly, as far as Massachusetts is concerned, in all honesty. OpenXML doesn't belong on any list of usable standards until it is one, a real one, where the playing field is even.

Instead, I gather from Weir's description that it's like traveling to a new town and asking for a map, but the directions are written in such a way that only longtime dwellers can read and follow them. You as a newcomer have no way to understand them and hence find your way around. If the directions say, "Go right when you get to the road where Nellie used to live until she married that musician and moved to Memphis," you don't know Nelly or where she lived before. Folks who have lived there all their lives know, and they have no trouble finding where to make the right turn, but you'll never find it. To make it worse, there is no promise from the map makers that if you do find out from one of the locals where Nelly used to live that they won't suddenly change the directions such that Nelly's house isn't used as the landmark any longer. It's Ted's silo. And you don't know Ted or his silo, and no one is willing to tell you. It's considered secret, proprietary information you are not entitled to. Now what do you do? That is the future that Massachusetts faces, sadly. But there you are.

Update: Groklaw member Winter informs me that it's not quite like the way I describe. Here's his analogy: "No, it is just a street directory, no map. Maps are only available for long time inhabitants. So you will be able to find an address in the directory, but no way to find the street in the town." In either analogy, you can't get where you want to go.

Why do I say that I think Massachusetts has lowered its standards? Let me show you some wording I notice on that same Massachusetts page the chart is on. When discussing how they choose a standard, they say this:


The ETRM is a living document, where open and/or de facto industry standards are continually evaluated for recommendation as Enterprise Standards. ITD’s Policy and Architecture unit keeps a “watch list” of current Enterprise Standards as well as emerging standards. The Enterprise Architecture Council (EAC) may recommend additions to the watch list.

The decision process outlined below is used to determine when standards should be recommended for adoption or deferred for review at a later date. Recommended revisions and additions to Enterprise Standards are presented to the EAC for discussion and consideration. Enterprise Standards recommended by the EAC are then put through an internal and public review process before being designated by the CIO as Enterprise Standards for Executive Department agencies.

Definitions Relevant to Decision Process

Open Standard - Specifications for systems that are publicly available and are developed by an open community and affirmed by a standards body. Hypertext Markup Language (HTML) is an example of an open standard. Open standards imply that multiple vendors can compete directly based on the features and performance of their products. It also implies that the existing information technology solution is portable and that it can be removed and replaced with that of another vendor with minimal effort and without major interruption. (Enterprise Open Standards Policy)

Open Format - The Commonwealth defines open formats as specifications for data file formats that are based on an underlying open standard, developed by an open community, affirmed and maintained by a standards body and are fully documented and publicly available. (ETRM, Information Domain)

De Facto Industry Standard - A de facto standard is a technical or other standard that is so dominant that everybody seems to follow it like an authorized standard. (Wikipedia)

The key criteria used for recommending an Enterprise Standard include determining whether

* There is existing or growing support around the use of the standard
* The standard interoperates with other relevant Enterprise Standards
* The standard can be adopted without causing negative business impact.

Interoperability isn't achieved to date, so far as I know, by either ODF or Open XML, and the bottleneck is Microsoft, I'm told. So, the Linux sellouts are helping Microsoft meet this requirement, not by true openness, but by whipping up some translators to work well enough that Microsoft can still keep its proprietary information to itself, which of course means that Microsoft will be able to make those translators not work well any time they choose.

Remember when Massachusetts told us that they wouldn't accept anything but open standards, open formats? Evidently no more, judging by that "and/or". If you look closely at the chart, after that first question, there are two more that any standard or format must be able to answer yes, but after that, it gets mushy, with two branches, one labeled "Open Standard" and the other "Not an Open Standard" and Massachusetts can choose from either branch. Folks, it doesn't get any clearer than this. Did a lobbyist write this stuff? [ Update 2: Joe Wilcox at Microsoft-Watch correctly remembers that this was exactly Microsoft's original argument, that it should qualify despite not being open or a standard, because a lot of people use it. What a coincidence.] In any case, whoever it was, they've lost sight of the goal, which was to be able to access documents a hundred years from now.

And notice the last bullet point? A standard can't be chosen if it would cause "negative business impact." It's undefined as to what that phrase means, and hence it's usable in a pinch to disqualify anything that isn't the monopoly's offering. All Microsoft has to do is make it impossible to interoperate well with its software. Heaven only knows they've got that down to a science. Remember DR DOS? WordPerfect ?

In other words, the criteria are now defined in such a way that Massachusetts can choose Microsoft's offering no matter what, despite it not being open or a true standard by any definition I understand, if push comes to shove, both of which I suspect have been going on in Massachusetts.

In case you think it's just me, here's Wilcox on the subject:

Microsoft seeks to solve these problems by releasing proprietary, XML-based OOXML and establishing it as as an accepted standard—and that simply isn't the same as creating a truly open standard.

Microsoft has long been in the position of establishing standards, and very much in a one-way fashion. Rather than truly open standards, where there is no single controlling company, Microsoft standards put the company in a commanding position — and this applies to recent OOXML and VC-1 standardization efforts.

The problem with politics is, it can't solve the following problem for Massachusetts: lock-in to a proprietary standard tied to a particular vendor -- even if it's a de facto standard, which Open XML certainly is not -- can indeed keep you from being able to open up your documents in fifty or a hundred years. Wasn't that the goal? What happened to that goal? It's what the open standards/open format requirement was supposed to ensure. Allowing a de facto standard that isn't open, that is proprietary, that ties you to a particular vendor pretty much ensures the failure of that policy.

Do you really believe Microsoft will still exist in a hundred years? Can you guarantee it? A company that can only get people to use their software like this? No wonder Louis Gutierrez quit.

So, for those of you who are less cynical than I am and wish to write to them and try to save them from themselves through education, here's some information you can use. No doubt you have your own ideas as well:

A review draft of ETRM v. 4.0 is available for review and comment from July 2nd through July 20th, 2007. Comments should be submitted to

It probably is worth writing in one sense: Massachusetts has always made the emails and letters public. If you are polite and helpful with urls to prove all technical points you make, it could be helpful for any other states trying to escape from lock-in.

It's a sad story for Massachusetts. I have visions of those poor government workers struggling with Vista, the operating system that shuts you off from your own documents if they suspect you have a pirated edition or haven't signed in to be tracked forevermore, and sometimes just because. Here is a poor soul begging the world to help him figure out how to make Vista compatible with XP, let alone with documents from competing operating systems. "But I need to finish editing that document! It's for the governor!" "I'm sorry. We're Microsoft. We don't care. We don't have to."

How ironic. Happy trails to you, folks. Here's something you might like to read, "How Vista Lets Microsoft Lock Users In" by Cory Doctorow, which includes this timely phrase: "No company has spent more time and money on preventing its competitors from reading its documents..." And here are six questions to ask yourself about Open XML. Here are two technical papers from the ODF Alliance website, “DIS 29500/OOXML Fact Sheet” and “The Technical Case Against DIS 29500/OOXML,” both PDFs.

And here's a tip: don't let politicians make technical decisions. They'll mess it up for you every time.

Update 3: A quotation from Bethann Pepoli, acting CIO of the Massachusetts Information Technology Division (ITD):

“Someone could submit a comment and we could make a review of ETRM and make changes,” she said. Those changes could include eliminating Open XML from ETRM in the final draft.”

To which Bob Sutor responds that Massachusetts is not a done deal:

If you live in Massachusetts and you care about this issue, you can comment via . I’ve posted a lot of links about this OOXML issue in the context of the JTC1 Fast Track proposal in another blog entry.

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