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To read comments to this article, go here
Now an OOXML Protest from Denmark's OSL - Updated 3Xs: Official English Translation
Saturday, May 31 2008 @ 02:00 PM EDT

ComputerWorld Denmark is reporting that a strong letter of protest has been sent to ISO from Open Source Leverandørforeningen in Denmark (OSL):
President Morten Kjærsgaard from OSL have today lodged an official complaint to the ISO Vice President Jacob Holmblad, who also sits as managing director of Danish Standard.

"Our appeal goes both on process with Danish Standard, but also to the lack of technical implementations in OOXML ISO level. Jacob Holmblad will appeal directly, because he has one foot in each camp," explains Morten Kjærsgaard to Computerworld....

Thus, the OSL in the wake of Jens Kjellerup, IT manager at the town executive for Children and Young People in Aarhus municipality, 14 days ago complained to the Danish Standard of OOXML process.

You can read a translation of the article or if you can, here's the letter [PDF] itself. If any of you can provide a translation of the letter, or refinements of the article's translation, please do.

Update: We have a translation of the letter now, thanks to Groklaw member KarlJorgensen. It states that ISO rules were broken, there was no consensus in Denmark, and that the Fast Track process "has been formally annulled for 2 months now - since the 29th of March, where the specification should have been sent to the national standardization organizations. The basis for a fast track procedure is no longer present, and I therefore expect ISO to pick up the case again." Read on for the full letter, and for clarity, it's a letter of protest, not an appeal from the standards body. However, it's a letter from a member of the technical committee who participated in the BRM and who raises serious concerns.

Update 3: We have the official English translation of the letter [PDF] now.

What I understand is that the complaint is based on the fact that Denmark's committee was seriously divided, and amendments they wanted to OOXML were never applied. And worse, they were arguing over an unfinished draft. How can that work well? No one can implement OOXML, and for as long as that is true, no one can interoperate with it. They ask that the matter be reopened.

Here's the part I'd like a clear and certain translation of:

Jacob Holmblad told to Computerworld that he will look at the complaint at the earliest opportunity. "The complaint was indeed sent to the ISO, but I like to send it on. Such a complaint is serious, and therefore it must also be dealt with seriously," says the Vice-President of ISO and the Director of the Danish Standard.

He takes next week to Geneva, where OOXML issue undoubtedly will be reversed with the ISO organization.

Update 2: Two readers say a more accurate translation would be: "He will go to Geneva next week, where the OOXML-issue will undoubtedly be raised with the ISO organization."

If you hover over each section, you will see the original language. This article seems to be raising a serious question. If there is no final draft yet, and for unknown reasons there isn't, and if Microsoft itself is not supporting OOXML yet, and it says it isn't, how is true interoperability possible? This couldn't be a deliberate delay game, could it? I hate to think that, but I confess this article has started me thinking in a brand new way about the delay in delivering the final draft. And since currently Microsoft isn't supporting ODF, only promising to do so someday, where does that leave interoperability? Finally, since ODF 1.1, as I understand it, has issues with spreadsheets and accessibility that are solved in ODF 1.2, why did Microsoft choose to support the version that works less well? Is their goal really interoperability or just the appearance of a willingness to do it someday?

Here's the official English translation of the entire letter as submitted 1 :

ISO
att: Vice-President Jacob Holmblad
[address]

Copenhagen, 30th May 2008

Complaint regarding the certification procedure in Danish Standards

Dear Jacob Holmblad

The Danish Open Source Businsess Association hereby submits a formal complaint regarding the certification procedures after the meetings in Danish Standards committee S-445 (previously S-142/U34) as well as the decision to change the Danish vote to a yes in connection with the treatment of DIS 29500. I write to you in your position as Vice-President for ISO,secondly as CEO for Danish Standards.

The Danish Open Source Business Association informed Danish Standards in a letter of March 22 2008 that the Danish requirements to DIS29500 have not been met. We summarized our points of views in the following five main points:

1. Microsoft's Office formats hinder interoperability
2. XML forms are missing
3. The complete specifications text is still not ready
4. Contradictory formulations
5. The maintenance of DIS29500 is not in place

I would also like to point out that after the round of hearings during the summer of 2007, agreement had been reached in the committee to formulate 168 change proposals and on this basis recommended a "No with comments". In order to change this position, according to Danish Standard's rules, there had to be a consensus in the committee. Furthermore, according to ISO's regulations, the complete specification must be ready at the latest 30 days after the BRM, so that the committee can consult the specification in order to verify to what extent the Danish technical objections were accommodated.

The discussion on the meeting March 26 was based on the unfinished specifications draft and on editorial notes from the BRM. This was far from sufficient to assure the committee that the 168 change proposals had been accommodated. Therefore, as you know, there was a great deal of disagreement during the meeting. Quite simply, we discussed specifications that did not yet exist.

Two months after Danish Standards announced the changed vote, we note that:

  • There never has been agreement in the committee regarding whether the Danish requirements were met
  • The five main points in our letter 22 March 2008 have still not been solved
  • The specification is still not ready, so that we can make certain that the change proposals have been incorporated

On this basis, the Danish Open Source Business Association ascertains that the procedures and the decision conflict with ISO's rules, and the process has caused considerable damage to the reputations of Danish Standards and ISO.

It is highly unusual that there are still no combined specifications, and I would like to bring to your attention the fact that Deputy Director of Danish Standards, Jesper Jerlang, in Danish Computerworld on May 22 admits that ISO's rules have been broken because Danish Standards has not received the final specifications. This is stated in section 13.12 in ISO's JTC 1 directive, which states:

"In not more than one month after the ballot resolution group meeting the SC Secretariat shall distribute the final report of the meeting and final DIS text in case of acceptance."

The process has thus been formally annulled now for 2 months -- since March 29, at which time the specifications should have been sent to the national standardization organizations. The prerequisites for the fast-track procedure no longer exist, and, therefore, I expect that ISO recommence the case.

I also expect that Danish Standards will inform ISO that it wishes ISO to recommence the case. The legitimacy of an ISO standard can only be sustained, when the certification process and foundation can not be called in question. An over-hasty, and therefore probably incorrect completion of one standard can bring other standards and the very system of standards in discredit.

Kind regards

Morten Kjærsgaard
Chairman of OSL


1 The Groklaw translation of the letter that we did originally follows, for the sake of history:

Copenhagen, 30th May 2008

Complaint over the certification process in Dansk Standard

Dear Jacob Holmblad

The Association for Open Source Vendors [OSL]hereby lodges a formal complaint to ISO over the certification process after the meetings n Dansk Standard's committee S-445 (former S-142/U34) as well as the decision to change the Danish vote to a yes in connection with the processing of DIS 29500. Thus I write to you in your capacity as vice president for ISO and as your capacity as executive director in Dansk Standard. I will send this complaint in English before the end of the month.

On the 22nd of May, the Association for Open Source Vendors made Dansk Standard aware that the Danish requirements for DIS29500 had not been fulfilled. We summarized our views in the following 5 main points (see attached letter)

1. Microsoft Office formats stand in the way of interoperability
2. XML schemas are missing
3. The finished specification is not available
4. Contradictory wording
5. The maintenance of DIS29500 has not been decided

Furthermore I would like to point out that after the round of hearings in the summer of 2007 there was agreement in the committee about formulating 168 requests for changes and based on that recommend a [vote of] "no with comments". According to Dansk Standard's rules, a concensus in the committee is required in order to change this recommendation, and according to ISO's rules a finished specification should be available (no later than 30 days after the BRM), which the committee could consult to verify that the Danish objections had been addressed.

The discussion on the meeting on the 26th of March in the JTC1-committee was based on the incomplete draft of the specification and on the editor's notes from the BRM. This was woefully inadequate to assure the committee that the 168 requests for changes had been addressed.

As a result, there was no agreement at the meeting (as you know). We simply discussed a specification which does not yet exist.

Two months after Dansk Standard's announcement of a change vote, we know:

  • there has never been agreement in the committee of whether the Danish requirements have been fulfilled.
  • the five points raised in our letter of of the 22nd of March have not yet been solved
  • and the specification is not yet available for us to ensure that the recommended changes have been incorporated.

Based on this, the association for open source vendors finds that both the process and decision is in violation of ISO's rules, and that the process has significantly damaged the reputations of both Dansk Standard and ISO.

It is very unusual that there still is no complete specification available, and I would like to draw your attention to Vice President in Dansk Standard, Jesper Jerlang in ComputerWorld on the 22nd recognizes that ISO's rules have been violated, as Dansk Standard has not yet received the final specification. This is evident from chapter 13.12 in ISO's JTC 1-directive, which reads:

"In not more than one month after the ballot resolution group meeting the SC Secretariat shall distribute the final report of the meeting and final DIS text in case of acceptance."

The process has been formally annulled for 2 months now - since the 29th of March, where the specification should have been sent to the national standardization organizations. The basis for a fast track procedure is no longer present, and I therefore expect ISO to pick up the case again.

At the the same time, I expect that Dansk Standard will communicate to ISO that the case should be re-opened. The integrity of an ISO standard can only be legitimately maintained by ensuring that there is no doubt around the approval process and approval criteria. A rushed and therefore possibly erroneous approval of even one standard can bring other standards into doubt and discredit the standardization process itself.

Regards

Morten Kjærsgaard
Head of OSL


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