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To read comments to this article, go here
ISO/IEC Recommendations on Appeals & Latest ODF News - Complete document as text
Friday, July 18 2008 @ 06:18 PM EDT

We have the entire ISO/IEC recommendations document [PDF] as text now, the memo with attachments, including all four of the appeals against OOXML, sent by Alan Bryden, Secretary-General and CEO, ISO, and Aharon Amit, General Secretary and CEO, IEC to the Technical Management Board regarding the disposition of the four appeals. They suggest deep sixing them.

Thank you to everyone for helping. Erwan has pulled it all together for us, a massive job, and he's created an index also, so you can quickly find what you are looking for, all in one place. I'll make this a permanent page, after we finish one other part of the effort, to insert links to materials referenced. Update: The permanent page is available now here.

Meanwhile, some rather odd things have been happening in OOXML/ODF land. First, Alex Brown, the convenor of the BRM, has put out a * press release* entitled OOXML will take second place following Microsoft’s announcement to support ODF, says Dr Alex Brown. He says this:

According to Dr Brown, OOXML will now represent the “legacy” of MS Office documents that the world has accumulated to date, following Microsoft’s announcement that its Office suite will add native support for ODF.
Is he a spokesman for Microsoft now? And why would you need a standard if all it does is represent old proprietary documents from a single vendor? Then we get to the scary part.

What do you get from this part of the press release?
ODF was intended to be an alternative to proprietary formats, including those used by Microsoft Office and other applications.

“Whatever Microsoft’s motivations, users are set to benefit from a world in which MS Office, easily the most used office software, has aligned itself with open, documented standards.”

I see a number of layers, but the one that makes me sit up straight is that I read it that Microsoft intends to take over ODF, if it can. And I also believe Brown is trying to justify his role in the OOXML process, the justification being that it is better to have Microsoft stuff in the hands of a standards body than in its own hands. And I can't help but notice what his company, Griffin Brown, does for a living. His partner in the business headed up the UK committee that voted Yes to OOXML.

Bob Sutor noticed the Brown press release too:

Alex was the convenor of the OOXML Ballot Resolution Meeting in Geneva in February. I’m guessing there was some commercial reason for making this statement in a press release vs., say, a simple blog entry, but it’s nice to have further “ODF has won” statements from the community associated with OOXML. This echoes comments by Stuart McKee, Microsoft’s US National Technology Officer.

The reason is, of course, so that we can see even more rapid adoption of this open standard office document file format. This will be through applications like Lotus Symphony, OpenOffice.org, KOffice, and real soon now, Microsoft Office 2007 in the next service package. We’ll get real interoperability and the value thereof for the worldwide community of office document users.

If ODF being proclaimed as the winner means that we now spend fewer resources dealing with the fading OOXML, I’m all for that. However, I’m also all for pushing through on the appeals process in ISO/IEC if it makes those organizations radically reform and repair the Fast Track process.

Brown expressed himself with more verve than in the press release in a blog post on his company blog, saying that opponents of OOXML have no longer any valid basis for opposing OOXML:

“What customers need is direct, internal support for ODF in MS Office”.

This is not a quote from Microsoft’s press release, but, a few days ago, from IBM’s Rob Weir – one of the most prominent and eloquent opponents of OOXML standardisation. His request is being answered. It becomes difficult to oppose Microsoft when they are systematically removing the stated reasons for opposition.

While the standards world contained many who argued against OOXML for entirely respectable reasons, the standardisation of OOXML also saw a concerted campaign against Microsoft from a variety of other quarters, including commercial competitors and some more extreme “activists” who are against any form of non-free software.

Microsoft’s move to support ODF now leaves very little reasonable ground for such opponents: those who are determined will surely be forced further into extremity. Some residual shrieks that Microsoft is trying to “extend and embrace” may linger, or maybe there will be mutterings that Microsoft are “poisoning the well” – but in the end these will be tired mantras that count for little – whether Microsoft is playing fair with their formats will become a testable fact. Religious arguments will not survive in that arena.

I disagree, obviously, but I think that is what the press release probably means, that it's another attempt by Brown to buttress OOXML and begin the new message going forward. And indeed there will be those of us who will notice Microsoft if it tries to extend, embrace and extinguish ODF, even if it does it through an advisory committee headed by Brown, or even if it just tries to morph it into its own image and twist it to its own purposes. I'm sure Microsoft would be very pleased if opposition to OOXML would come to an end. But that isn't going to happen. The EU Commission has stated publicly it will be watching how well Microsoft implements ODF, and the issue, I'm thinking, might be that ODF does not exclude commercial GPL programmers and vendors. How is Microsoft going to fully implement it, without actually being open? What to do? What to do? Take over ODF and have it run by Microsoft folks? It worked with OOXML, after all.

When you read this ISO/IEC document, ask yourself if you would need to be an extremist to find the OOXML handling, including by Brown himself, appalling? Or is the problem that the proprietary world has become so used to dirty tricks and overbearing behavior, they've lost the ability to feel when things are seriously wrong? Of course people will continue to notice.

Rick Jelliffe then responded to Sutor, but significantly, he attacked OASIS: "JTC1's process, based on National Body voting is both effective ... and more genuinely open, because it is impossible to stack either directly or indirecty."

Heh heh. He gave his interpretation of the Brown press release:

This week, Alex Brown (who was asked to organize next week's meeting in London to figure out the best way to maintain —fix, complete, evolve, retire—OOXML at SC34 which is the ISO/IC JTC1 committee charged with looking after OOXML and ODF) issued a press release which takes a similar view: The recently standardised OOXML format will now take second place to Open Document Format (ODF)....

I presume the reason for Dr Brown's press release is quite simple and innocent: to put it on the record that his view is pro-standards and pro-ODF but there are benefits to having both ODF and OOXML as ISO standards.

Nothing is simple when Microsoft is in the picture. I think it's obvious from all this that indeed Brown worked hard to get OOXML as an ISO standard. And he still publicly supports it, even after the four appeals to OOXML have highlighted such serious flaws in the process. Is that the convenor's role, though? If ever it was unclear where Brown stands, it's obvious now, to me anyway. But the attack on OASIS is, I believe, tied to the new strategy, to take over control of ODF going forward. It's the key to understanding the agenda, I believe.

Rob Weir replied to Jelliffe, in an article titled, "What is Rick Smoking?" in which he makes mincemeat of the idea that OASIS is less open than JTC1/SC34. Here's a small snip:

What about transparency? As Rick demonstrates, OASIS meeting minutes and agenda are all posted and public. So is our mailing list. So are all of our drafts. So is our member and public comments.

But in JTC1/SC34, most of the documents are private, only accessible to SC34 members by password. And then occasionally JTC1 will step in prevent SC34 from releasing their own work , suppressing documents even from their own SC members. There are no public comments to speak of, and member comments on draft standards are secret.

Bottom line to me? I think Microsoft sees a way to make some money with ODF, but it wants to change it to suit its own needs better. It didn't participate in the ODF process, although it was free to suggest anything it wanted. Now, when it looks like the world really does want ODF instead of OOXML, surrogates are sending a dual message -- first, that ODF has won, so OOXML isn't worth fighting any more (and anyone who does is an "extremist" anti-Microsoft whiner), and two, that OASIS isn't able to do a good job with ODF, so the same folks who brought you OOXML should take it over. I can't see otherwise why Jelliffe would damage his reputation by writing something so laughable. In short, I believe the whole OOXML-type of behavior has just begun again, but with a new goal and in a new context. And with the usual suspects carrying the baton.

So, here's the latest on that front, from another article by Rob Weir, "Toy Soldiers" in which he gives his view of the meeting to be held in London to discuss a proposal by SC34:

One example is the proposals in SC34 to create a new project to create a Technical Report on translating between ODF 1.0 and OOXML 1.0. This might have made sense at some point in the past. But this proposal seems out of place now.

Consider:

1. No one supports ODF 1.0 today. All of the major vendors have moved on to ODF 1.1, and will be moving on to ODF 1.2 soon.

2. No one supports OOXML 1.0 today, not even Microsoft.

3. No one supports interoperability via translation, not Sun in their Plugin, not Novell in their OOXML support, and not Microsoft in their announced ODF support in Office 2007 SP2.

So the proposal essentially will be to create an technical report for a translation task that no vendor is implementing, between versions of the ODF and OOXML standards that no vendor is supporting.

Excuse me if my enthusiasm is muted.

And yes, the proposers want accelerated processing for this proposal. But the idea was already obsolete the day it was proposed to SC34. Events have overtaken it, though the clockwork motions continue, and SC34 is currently having a ballot for this proposal, ending on 29 July. I'm not in favor of it. Perhaps it would be worth considering if resubmitted in one year's time, and was targetted to consider ODF 1.2 and OOXML 1.1 (or whatever their next version is). But is it really a priority for SC34 now?

Another example of working on autopilot is the ad-hoc working group in SC34 looking at OOXML maintenance. Although it was heralded with much pomp "SC takes control of OOXML", the fact is SC34 currently can't even look at OOXML, let alone maintain it. They are entirely impotent. But still they will go through the motions and meet next week in London to advise Alex Brown, who will then take all this advice and later formulate and write up his OOXML maintenance plan for SC34 to vote on.

All the best to them. They voted on OOXML without seeing it. Now they'll determine how to maintain it without seeing it. Maybe ISO should stand for Invisible Standards Organization? Maybe one of the participants can let me know where can I submit my invisible defect report?

In any case, since Microsoft has effective voting control of SC34, after almost two years of packing the committee, my bet is that OOXML will effectively be handed over to Ecma for maintenance. That is what JTC1 has done for every other Ecma Fast Track that has been approved. They might call it a "maintenance group" and allow token participation from SC34 liaisons in a non-voting capacity, but in all important ways it will remain Microsoft/Ecma standard....

Given the leisure to do the job right, my bet is on Microsoft. Everyone knows it for what it is now. There is no longer need for elaborate attempts to disguise the fact that OOXML is and will remain a Microsoft-only standard. Why continue the charade?

Because Microsoft's not done until ODF won't run? By that I mean, run as it does. They are not meeting for nothing, in my opinion. It's not busywork. There is an agenda, no longer quite so hidden. It's the opening part of the effort to take over ODF control, I think, so Microsoft can make it less open, probably, so as to make buckets of money from it, without Microsoft having to actually be open. On that page on What is Rick Smoking?, you'll find a list of who was to go to the meeting of this advisory group, and a commenter says, "So a quick tally shows that there will be 25 participants, of which 12 are Ecma TC45 members (as listed) or Microsoft employees (Brett Roberts, Dave Welsh, Jasper Bojsen, Kimmo Bergius, Shahzad Rana and Wemba Opota)."

Get the picture? Is that who you want in charge of ODF?

And with that, here's the index to the ISO/IEC memo, followed by the text version of the document.


Groklaw's Index to the Document

Title Source Groklaw Page
Vote/Information-Form Number: 078/2008 ISO [Article] 1

ANNEX A ISO
2

Attachment 1 to annex A - Claimed grounds for appeal and corresponding evaluations by the ISO & IEC CEOs ISO [Article] 5

Attachment 2 to annex A - Additional grounds submitted in BR, VE (2008-06-24) & ZA (2008-06-25) letters: ISO [Article] 7

Annex B



Text of the appeals



Text of the South African appeal SABS [Article] 8

Text of the Brazilian appeal ABNT [Article] 11

Text of the Indian appeal BIS [Article] 13

Text of the Venezuelan appeal FONDONORMA [Article] 15

Example of letter sent to all appellants ISO
17

Further correspondance



Further Brazilean correspondence on requested remedial actions ABNT
18

Further South African correspondence on requested remedial actions



Cover letter SABS
22

DIS 29500: Requested specific remedial actions – South Africa SABS
23

Annex 1: MICROSOFT PRESS RELEASE SABS
27

Further Venezuelan correspondence on requested remedial actions FONDONORMA
28

Annex 1 – BRM Vote Breakdown Table FONDONORMA [Article] 31

Annex 2 – Standing Issues as presented by VE FONDONORMA [Article] 32


And here is the document as text:

***********************************************************

TMB Secretariat
Vote/Information-Form
Number: 078/2008
Date: 2008-07-04

ISO TECHNICAL MANAGEMENT BOARD

SUBJECT
Appeals on ISO/IEC DIS 29500 Open Office XML

BACKGROUND

ISO/IEC DIS 29500, OOXML, was circulated for voting under JTC 1's Fast Track Procedure (note that this differs from that used in the rest of ISO and IEC) in April 2007 following a one month internal review within ISO/IEC JTC 1. Following that vote, which resulted in insufficient votes for approval, a Ballot Resolution Meeting (BRM) was held in February 2008. After the BRM, the JTC 1 national bodies had 30 days in which to confirm or change their votes and at the end of this period, sufficient votes to approve the document were obtained.

JTC 1's appeals procedure resulted in 4 appeals being received. These appeals have been reviewed by the ISO Secretary-General and IEC General Secretary and are being submitted, in accordance with the JTC 1 procedures, to the ISO/TMB and IEC/SMB.

Full information is given in:
Annex A: CEOs' comments
Annex B: Appeals from ABNT (Brazil), BIS (India), FONDONORMA (Venezuela) and SABS (South Africa) (together with further correspondence on requested remedial actions)

ACTION

The members of the Technical Management Board are invited to indicate, by replying yes, no or abstention on EITHER a) OR b) for each of the four appeals (see item 14 in annex A):


a) not to process the appeal any further:
Item 1 ABNT
Item 2 BIS
Item 3 FONDONORMA
Item 4 SABS

OR

b) to process one or more of the appeals, which would require setting up of a conciliation panel
Item 5 ABNT
Item 6 BIS
Item 7 FONDONORMA
Item 8 SABS



by no later than 4 August 2008


HG/TMB_VF078_2008

(1)

ANNEX A

From: Alan Bryden, Secretary-General and CEO, ISO
Aharon Amit, General Secretary and CEO, IEC
To: Technical Management Board (TMB), ISO
Standardization Management Board (SMB), IEC
Subject: Appeals received concerning approval for publication by ISO/IEC JTC 1 of
ISO/IEC DIS 29500 (Office Open XML)
Date: 2008-06-30

Background
1. In 2006 Microsoft proposed an XML version of the formats of its Microsoft Office documents (used in the products Word, Excel and PowerPoint) to Ecma International (“Ecma”) for standardization.
2. After work by Ecma Technical Committee 45 with members from Apple, Barclays Capital, BP, The British Library, Essilor, Intel, Microsoft, NextPage, Novell, Statoil, Toshiba, and the US Library of Congress, ECMA 376 was published in December 2006.
3. On 2006-12-20 Ecma—as an A-liaison—submitted ECMA 376 for fast-track standardization in ISO/IEC JTC 1. Note that the Directives governing fast-track standardization in ISO/IEC JTC 11 are different from those in the ISO/IEC Directives, Part 1.
4. On 2007-01-05 ECMA 376 was submitted to National Bodies (NBs) for the 30-day “review” period mandated by the rules, asking them to notify any “contradictions”2. 20 NB replies were received, and Ecma provided a response to each of them. The replies and Ecma responses were distributed to all NBs on 2007-03-01, and were also enclosed with the DIS sent for NB voting (see 5. below).
5. As specified in the rules, the perceived contradictions were “addressed by the ITTF3 and JTC 1 Secretariat”, which came to the conclusion that the issues raised could only be settled by the NBs, and that therefore the planned five-month DIS vote should proceed. The vote took place from 2007-04-03 to 2007-09-02 according to the “combined voting procedure” which involves all ISO and IEC national bodies (not just ISO/IEC JTC 1 P- or O-members). 87 NBs voted, and the acceptance criteria were not met: only 53 % of P-members (min. 66.66 %) and 74 % of all NBs (min. 75 %) voted to approve.
6. In accordance with the JTC 1 Directives, a “ballot resolution meeting” (BRM) was arranged by ISO/IEC JTC 1/SC 34, the subcommittee to which the standard (once approved) would be allocated for maintenance. The JTC 1 rules specify that such a BRM should normally be held, and that at its conclusion—if the acceptance criteria (66.66 % and 75 %) are met—the standard should be published,. The BRM took place on 2008-02-25..29 in Geneva; a full list of answers to “frequently asked questions” (FAQ) concerning the Directives, their interpretation and the procedures governing the BRM had previously been made available to all NBs in November 2007 (JTC 1/SC 34 N 932). The full results of the BRM, consisting of Resolutions (editing instructions) and notes, were published on 2008-03-06 and served to allow the national bodies to determine whether they wished to maintain or change their original votes.

1 The ISO/IEC JTC 1 Directives, replacing Part 1 of the ISO/IEC Directives, may be found in their entirety at
http://isotc.iso.org/livelink/ livelink.exe/3959538/Jtc1_Directives.pdf? func=doc.Fetch&nodeid=3959538.
2 The rules mention “perceived contradiction with other standards or approved projects of JTC 1, ISO or IEC”.
3 ITTF = Information Technology Task Force, ISO C.S. and IEC C.O. function supporting ISO/IEC JTC 1.

2 / 37 SMB/3774/QP

7. The rules include a provision that “after the deliberations” of the BRM, NBs have an opportunity to decide whether they wish to change their votes on the basis of the actions taken on their comments. There is no provision that a final text be provided at that stage. Because of the controversy surrounding the project and the consequent need to guarantee each NB a fair chance to express its decision, NBs could notify a change in their vote by midnight on 2008-03-29.
8. On 2008-04-02 IEC and ISO announced that the acceptance criteria had now been met (75 % and 86 % respectively).
Appeals received
9. By the two-month deadline for appeals (2008-06-02) four appeals had been received:
• Brazil • India • South Africa • Venezuela.
10. The South African appeal (submitted on 2008-05-23) and comments from ITTF were included for information in the SMB and TMB agendas (meetings 2008-06-02..03), but the appeal was not formally submitted to the TMB and SMB at that time.
11. The CEOs determined that none of the four appeals satisfied the condition laid down in 11.1.4 that “the specific remedial action(s) that would satisfy the appellant’s concerns” shall be stated. They therefore wrote to the appellants on 2008-06-12 requesting this information by 2008-06-25. By this date India, Brazil, South Africa and Venezuela had responded and the responses are included in annex B following the appeals.
Formal situation
12. The present document constitutes the formal submission of the four appeals by the CEOs to the TMB and the SMB.
13. Brazil is not a P-member of ISO/IEC JTC 1 and technically does not have a right to appeal a JTC 1 decision.
14. The TMB and the SMB may choose one of two options for each appeal:

14.1 Not to process the appeal any further. This is the equivalent of denying the appeal. If all four are denied, publication of ISO/IEC 29500 may proceed. The NB concerned may appeal this decision to the Councils.
14.2 Process the appeal further. This has the consequence that a conciliation panel must be organized. In this event it seems indicated to organize a single conciliation panel for all the appeals being processed.
Evaluation of the appeals
15. The appeal from India identifies a “remedial action”, extending the time for appealing to allow reading the “final text”, which is irrelevant to the decision being appealed and therefore to the appeal (see item 6. in Attachment 1). Therefore the Indian appeal identifies no remedial action and is not receivable.
16. The appeal from Brazil proposes a remedial action of cancelling the voting result and putting the project back to the new work item proposal stage, not on the fast track. That from South Africa proposes rediscussing and revoting on “794” edits, all of which were voted on by NBs at the BRM, according to a procedure also approved by NBs at the BRM. That from Venezuela proposes cancelling the voting result and putting the project back to the CD stage (not fast
track). These actions, reversing decisions reached in accordance with due process by the

3 / 37 SMB/3774/QP


members of ISO and IEC, would require demonstration of serious procedural problems in the voting.
17. Several further remedial actions are identified by South Africa and Venezuela; of these,
changing the title may be relevant if it is technically justified and if the appeal is upheld.
Proposed “remedial actions” which are not pertinent to the appeal include instructions to SC
34, provision of the text resulting from the BRM, and several suggested modifications to the
Directives.
18. The replies from Brazil, Venezuela and South Africa contain much material which is not
relevant to completing their existing appeals with the addition of remedial action(s). That from
South Africa in particular is a wide-ranging discussion of standardizing such a specification,
makes many valid points and recommendations for the future while also containing errors of
fact, and in these respects does not concern the appeal sent in May.
19. Attachment 1 contains a summary of the distinct grounds for appeal claimed in the four appeals, together with an explanation from the ISO and IEC CEOs for each one.
Recommendation
20. The processing of the ISO/IEC DIS 29500 project has been conducted in conformity with the ISO/IEC JTC 1 Directives, with decisions determined by the votes expressed by the relevant ISO and IEC national bodies under their own responsibility, and consequently, for the reasons mentioned above, the appeals should not be processed further.

4 / 37 SMB/3774/QP

Attachment 1 to annex A

Claimed grounds for appeal and corresponding evaluations by the ISO & IEC CEOs

The following distinct claimed grounds for appeal may be identified in the four appeals. For each a brief explanation and evaluation is given.

1. Incorrect application of ISO/IEC JTC 1 Directive 13.4 to address claimed "contradictions" identified during the 30-day review period before the DIS ballot, including not informing NBs of the claimed contradictions.

1e. Not correct. The Directives give the JTC 1 Secretariat and ITTF latitude to use judgement as to whether a meeting should be organized to address alleged contradictions. Considering that other issues could potentially be identified during the DIS ballot, the JTC 1 secretariat and ITTF concluded that it was preferable to initiate the ballot and to allow all issues to be addressed by the BRM. The NBs were fully informed of all the claimed contradictions and Ecma's responses to them.

2. BRM not conducted in accordance with ISO/IEC JTC 1 Directives 9.1.4, but with 9.5 instead, in spite of the fact that it was not a "letter ballot"

2e. Correct but inapplicable. The BRM was neither a meeting of the JTC 1 nor of SC 34 but was open to all 87 national bodies which submitted a vote (including abstentions) on the DIS. Applying 9.1.4 would have disenfranchised the voting NBs present at the BRM which were not P-members. The fact that any votes in the BRM would be open to all national delegations present was communicated over three months prior to the BRM.

3. BRM did not take into account NBs' efforts during the meeting to reach consensus on modifications to the proposed responses from the Project Editor.

3e. Not correct. The resolutions of the BRM document decisions taken where consensus was reached.

4. BRM "inconclusive", too short, arbitrarily short, or otherwise incorrectly conducted.

4e. Not correct. Decisions on the comments not discussed during the BRM and proposed dispositions were taken by a process agreed by the BRM itself (29 votes in favour, none against and 2 abstentions.

5. Final report of the BRM not issued.

5e. Not correct. The final report of the BRM was issued on 2008-03-06.

6. "Final" text of ISO/IEC 29500 or ISO/IEC DIS 29500, or "revised FDIS text", not released

6e. Correct but irrelevant. The decision being appealed is the JTC 1 decision to approve the draft. The text mentioned in the Directives and by the appellants is not germane to that decision, which must be taken on the basis of the original DIS text and the actions taken by the BRM on the comments. The provisions of any revised text is not for purposes of further decision by NBs.

5/37 SMB/3774/QP

7. Document "as submitted by Ecma and as modified by the BRM is not ready for fast track processing"
7e. A matter for NBs' judgement, which they expressed through their positive or negative vote on the draft.

8. Document does not follow ISO guidelines for presentation of standards.

8e. Correct but irrelevant. Fast-track submissions need not follow ISO or IEC guidelines for presentation of standards. The corresponding standard must be made to follow the guidelines from its next revision onwards (see JTC 1 Directives, 13).

9. NBs were required to analyze far too much information in far too little time.

9e. A matter for NBs' judgement, which they expressed through their positive or negative vote on the draft.

10. Process followed was incompatible with the principles of consensus, technically-oriented discussions and "redundancy of standards", was dominated by large multinational organization(s), and has harmed the reputations of both ISO and the IEC

10e. Insofar as observation of Statutes, Rules of Procedure, Directives and other rules is concerned, this is not correct. Otherwise it is a matter for NBs' judgement, which they expressed through their positive or negative vote on the draft.

6/37 SMB/3774/QP

Attachment 2 to annex A

Additional grounds submitted in BR, VE (2008-06-24) & ZA (2008-06-25) letters:

11. Fast-track process was handled by ISO/IEC JTC 1 instead of SC 34
11e. Not correct. No actions identified in the Directives as SC actions were carried out by JTC 1 Secretariat according to Directives 13.2, second bullet

12. "Contradictions" (cf. point 1, above) were not adequately handled by ITTF and JTC 1 Secretariat according to Directives 13.2, second bullet

12e. Not correct. See 1e.

13. Voting should have been conducted electronically rather than at a meeting

13e. Not correct. The Directives require a physical meeting, and say nothing about a voting process distinct from the meeting.

14. Discussing "only 67 out of the 1027" proposed resolutions "does not constitute a successful conclusion of the BRM"

14e. Not correct. All the proposed resolutions were decided according to well-defined voting procedures accepted by the NBs; all NBs had the opportunity to raise priority items; all those raised by NBs as priority items were discussed. Whether the conclusion of the BRM was successful is for NBs to decide; by their votes, they have done so

15. Important topics were postponed and finally not discussed in the BRM

15e. Not correct. See 14e.

16. Title of standard doesn't reflect contents

16e. Not correct technically; otherwise a matter for NBs' judgement, which they have expressed in their vote.

17. Proposal of US & BR on legacy mapping and division into parts not considered, in spite of "a chorus of objections"

17e. Not correct. See also 3e and 14e.

18. It is wrong to delay SC 34 ad hoc groups' work until standard is published

18e. Irrelevant. (Additionally, if not delayed, SC 34's activity may interfere with the process of dealing with the present appeals.)

19. Except for political pressure, it would be best to publish only after these groups have completed their work

19e. Irrelevant. (It is also not correct. It would be a violation of the Directives.]

20. Ecma should have had no role in making the judgement referred to in 1 and 1e

20e. Correct. Ecma did in fact have no role in this judgement.

7/37 SMB/3774/QP

Annex B
Text of the appeals

SABS
Your ref :
Our ref : 14/2/ICT/TC71/8/29500 iec
Enquiries : GR Visser
Telephone : [phone]
Date : 2008-05-22

General Secretary, International Electrotechnical Commission
Attention: Mr R Amit
[address]
Switzerland

Dear Sir

Appeal from the South African national body regarding the outcome of
the fast-track processing of DIS 29500 Office open XML

The national body of South Africa (SABS), as a P member of JTC 1, hereby submits an appeal against the outcome of the fast track processing of DIS 29500 Office open XML. This is based on the procedures followed before and during the ballot resolution meeting (BRM) held from 25 to 29 February 2008 to discuss the comments submitted on the fast-tracked DIS 29500 and the proposed responses from Ecma.

In addition, South Africa wishes to register its deep concern over the increasing tendency of international organizations to use the JTC 1 processes to circumvent the consensus-building process that is the cornerstone to the success and the international acceptance of ISO and IEC standards. The ability of large multi-national organizations to influence many national bodies, with the resultant block-voting over-riding legitimate issues raised by other countries, is also of concern.

This appeal is made in accordance with Clause 11.1.2: "A P member of JTC 1 or an SC may appeal against any action, or inaction, on the part of JTC 1 or an SC when the P member considers that in such action or inaction:

- questions of principle are involved;
- the contents of a draft may be detrimental to the reputation of IEC or ISO; or
- the point giving rise to objection was not known to JTC 1 or SC during earlier discussions."

We believe that there is an important question of principle involved and that the reputation of ISO/IEC is indeed at stake. There has been speculation about the need to revise the directives around fast track processing. While such revision might indeed be necessary, we cannot accept the outcome of a process in which the existing directives have not, in our opinion, been applied.

Reasons for appeal

We are of the opinion that in the following instances the ISO/IEC JTC 1 Directives, Edition 5 have not been followed.

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1. Clause 13.4, second paragraph states "During the 30-day review period, a NB may identify to the JTC 1 Secretariat any perceived contradiction with other standards or approved projects of JTC 1, ISO or IEC.

If such a contradiction is alleged, the matter shall be addressed by the ITTF and JTC 1 Secretariat in accordance with Section 13.2 before ballot voting can commence. If no contradiction is alleged, the 5 month fast-track ballot voting commences immediately following the 30-day period. If a contradiction is alleged, the JTC 1 Secretariat and ITTF shall make a best effort to resolve the matter in no more than a three month period, consulting with the proposer of the fast-track document, the NB(s) raising the claim of contradiction and others, as they deem necessary. A meeting of these parties, open to all NBs, may be convened by the JTC 1 Secretariat, if required."

Whereas various NBs raised contradictions in the period, there is no evidence that "A meeting of these parties, open to all NBs" was held and that the results were made available to the other participating NBs. We understand that after Ecma was afforded a chance to address the NB comments submitted regarding contradictions, the JTC 1 Chairman, Secretariat and ITTF staff decided that convening a meeting to discuss contradictions would not be productive and that the best way to proceed would be to issue the draft for ballot without delay. The other NBs were not informed about the alleged contradictions but only informed, in the HOD meeting immediately prior to the BRM, that any issues of contradictions raised during the BRM would be ruled out of order by the BRM Chairman. Given this instruction, and given the fact that despite such instruction, a number of NBs continued to raise contradictions both in their written comments and during the BRM, it is clear that the JTC 1 Chairman, Secretariat and ITTF should have seen that a meeting of parties, as envisaged in the Directives, was indeed a necessity. Attachment 1, Item 1

2. Clause 13.8 states that "At the ballot resolution group meeting, decisions should be reached preferably by concensus. If a vote is unavoidable the vote of the NBs will be taken according to normal JTC 1 procedures."

Since only 67 of the 1027 responses by Ecma were discussed, the processes used to 'approve' the remaining responses by voting were questionable and did nothing to promote concensus, but simply 'approved' Ecma's attempt to improve the quality of the standard. This was especially disconcerting to the large number of experts from various countries who had spent many hours in ad hoc meetings during the period of the BRM to develop consensus on some of the Ecma responses that contained errors or other issues of contention. The decision to ignore such important proposals for improving the standard and to resort to blanket voting on all issues not resolved during the discussions (more than three quarters of the responses were never tabled during the BRM) was procedurally flawed. Effectively, this required the national bodies to write a blank cheque approving the proposals of the authors of the proposed standard, which is inappropriate for any standard, never mind one that has generated considerable controversy. Attachment 1, Item 4 and Attachment 2, Item 14

There has been some dispute over what "normal" procedures should be in such a case. the general directive for meetings is as follows:

Clause 9.14 "In a meeting, except as otherwise specified in these directives, questions are decided by a majority of the votes cast at the meeting by P members expressing either approval or disapproval." However, since many of the countries represented were not P members of JTC 1, the actual voting during the BRM was conducted according to clause 9.5 Combined Voting Procedure that states "The voting procedure which uses simultaneous voting (one vote per country) by the P-members for JTC 1 and by all ISO member bodies and IEC national committees on a letter ballot is called the combined voting procedure. This procedure shall be used on FDISs,

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DISs, FDAMs, DAMs and FDISPs." The decision to use this interpretation was incorrect since the voting during the BRM was not a letter ballot. While we are aware that the Convenor, in consultation with representative from ITTF and the IEC representative decided otherwise, we challenge this interpretation and therefore the result of the voting that was based upon that interpretation. Attachment 1, Item 2

3. Clause 13.12, last bullet point: "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." Up to date of writing, neither the final report of the BRM meeting or the revised FDIS text has been circulated by the SC Secretariat. The only communication to NBs (other than press releases) has been 34N1015, which was the result of the revised voting during the 30-day period subsequent to the BRM. There is no indication of when the final DIS text might be expected but it has not been distributed within the one month period prescribed.

Given the magnitude of the specification and the number of identified edits required it was clear that this directive could not have been met. This is the clearest possible indication that DIS 29500 as submitted by Ecma and as modified by the BRM is not ready for fast track processing. It was not incumbent on the participants of the BRM to modify this clearly stated requirement. Attachment 1, Items 5 and 6

Conclusion

In conclusion, South Africa challenges the validity of a final vote that we contend was based upon inadequate information resulting from a poorly conducted BRM. Moreover, we challenge the validity of a process that, from beginning to end, required all parties involved to analyze far too much information in far too little time, involved a BRM that did not remotely provide enough time to perform the appointed purpose of that procedure, and for which an arbitrary time limitation was imposed to discuss and resolve a significant number of substantial responses, despite the Directives not requiring any such limitation as to duration.

It is our opinion that the process followed during all stages of this fast track has harmed the reputations of both ISO and the IEC and brought the processes enshrined in the Directives into disrepute, and that this negative publicity has in turn also harmed the reputations of all member bodies of ISO and the IEC.

Yours faithfully

(signature)
Mr M Kuscus
South African Bureau of Standards (SABS)

cc ISO TMB Secretary (Mr Mike Smith)
IEC SMB Secretary (Mr Jack Sheldon)
ISO/IEC JTC 1 Chairperson (Mr Scott Jameson [email])
ISO/IEC Secretariat (Ms Lisa Rajchel [email])

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From: ISOTC [email]
Sent: Thursday, May 29, 2008 3:50 PM
To: Lisa Rajchel; [email] Cc: [email]; [email]; Scott Jameson; [email]; Toshiko Kimura; Marcia Cristina Oliveira; 'Eugenio De Simone'; 'Milena Pires - Normalização'
Subject : Formal Appeal

Dear Sirs,

The Associação Brasileira de Normas Técnicas (ABNT), as a P member of ISO/IEC/JTC1/SC34, would like to present, to ISO/IEC/JTC1 and ISO/IEC/JTC1/SC34, this appeal for reconsideration of the ISO/IEC DIS 29500 final result.

This appeal is based on two main considerations:

  1. Brazil considers that the BRM was inconclusive.
  2. Brazil considers that the final version of the ISO/IEC DIS 29500 text shall be released immediately.

1. About the BRM

At the BRM, the Brazilian delegation was not allowed to present an important proposal regarding the legacy binary mapping. This proposal was a complementary part of USA delegation proposal regarding the new organization of the ISO/IEC DIS 29500. It also shall complement the scope change proposal approved at the BRM.

Brazil has tried to present this proposal, during the debates, on the first day of the meeting and, attending to a request made by the convenor, Brazil has taken offline discussions with USA and other delegations and prepared its proposal to be presented on Friday, during USA proposal presentation.

On Friday, when USA ended their part of presentation and asked for Brazil to present its part of it, the convenor denied this opportunity to Brazilian delegation.

Several delegations has protested against that arbitrary decision, but those appeal was in vain and until the end of the BRM, the Brazilian delegation was not able to present its proposal. The main reason alleged by the convenor was "lack of time". Attachment 2, Item 14

The proposal here mentioned, is the one available on the file "Br_Multipart_Proposal.ppt" available to all BRM members the ISO/IEC/JTC1/SC34 website at least since the fourth day of the meeting.

Brazil also noticed that most of the decisions taken during the BRM were based on the "lack of time" argument, and we think that this is completely incompatible with the kind of decisions that should have be taken on that meeting.

During the BRM, some decisions were also taken based on the argument that "we need to give answers to journalists", and we think that the media coverage of that meeting was not so important as the meeting results, to be used as a decision making criteria.

Even with the "lack of time" alleged, some members of ECMA delegation, and not members of any NB, was allowed to do half-hour speeches during the two first days of the meeting.

The voting rules of that meeting were not taken in accordance with ISO/IEC/JTC1 directives subclause 9.1.4. Brazil also notes that the ISO/IEC DIS 29500 was voted under ISO/IEC/JTC1 but the BRM was organized by ISO/IEC/JTC1/SC34. Even if the directives subclause 9.1.4 was intended to be used, Brazil cannot understand if the P member status considered, should be the ISO/IEC/JTC1 or the ISO/IEC/JTC1/SC34 one. Attachment 1, Item 2

Brazil also considers that if most part of the issues was to be decided by vote, without any kind of discussion allowed.

About the same subject, Brazil considers that the elected "default voting criteria" was only elected because it was the "less bad" criteria that could be analyzed, and we do not consider that this voting decision represents the intent of the vast majority of BRM delegates. They went there to discuss the technical propositions.

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Analyzing the document "SC 34 N 990 - EDITED NOTES OF THE MEETING", on page 7, we have found the register of BR objection to the multi-part split decision but analyzing the document "SC 34 N 989 - RESOLUTIONS OF THE MEETING" we do not find that objection registered.

During the BRM, the delegations were asked to vote in block for the rejection of a set of responses that was considered by the convenor as "responses without any editing instructions". Those responses are listed on the file "dis29500-nochange.txt", available at the SC34 website during the BRM and, as far as Brazilian delegates remember, this set of responses was "rejected in block" as requested.

When we analyze the documents N989 and N990 we do not see any reference to that decision and also at the ISO/IEC/JTC1/SC34 document with title "Result of Proposed disposition of comments (SC 34 N 980)", that presents a table with the status of each response, some of the "block rejected responses" appears as accepted (e.g. responses 3, 5, 10 and 11 among others).

To finalize our considerations about the BRM, analyzing the document N 989, we've found that the BRM can be summarized by:

Total of responses available for discussion: 1027 100 %
Total of responses addressed at the BRM: 189 18,4 %
Total of responses decided by "default" vote: 838 81,6 %

We use the term "responses addressed at the BRM" above because the majority of those responses was decided by block vote without any discussion at the BRM.

For the above-mentioned reasons, Brazil considers that the ISO/IEC DIS 29500 BRM was inconclusive. Attachment 1, Item 4

2. About the final version of ISO/IEC DIS 29500 text

According to the directive item 13.12, the final version of the ISO/IEC DIS 29500 text shall be distributed on not more than one month after the end of the BRM.

Seen that almost three months has passed after the end of BRM, without any final version of the text distributed or published, and based on directive subclause 13.12, Brazil request the distribution of ISO/IEC DIS 29500 final text.

For all those reasons presented, Brazil kindly request that the final result of ISO/IEC DIS 29500 should be reconsidered by ISO/IEC/JTC1 and ISO/IEC/JTC1/SC34. Attachment 1, Item 6

Best regards,
Marcia Cristina de Oliveira
ABNT — Manager Standardization Process

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Rakesh Kacker, IAS
Director General
BUREAU OF INDIAN STANDARDS
[address]

Our Ref: LITD/ADGT/Misc

Mr Alan Bryden
ISO Secretary General
ISO Central Secretariat
[address]

Subject: Appeal from Indian National Body regarding ISO 29500 OOXML

Dear Sir

The Indian National Body (BIS) hereby submits the following appeal under provision of Clause 11 of JTC 1 directives in reference to ISO 29500 OOXML:

During the Ballot Resolution Meeting (BRM) on 25-29Feb 2008, a large number of modifications were decided to be made in the document. The whole document was restructured and scopes of different parts were modified.

As per 13.12 of JTC 1 directives it is stated that "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." However, the final text incorporating the modifications, as envisaged in the BRM is not available even as on date, thus violating JTC 1 directive. Attachment 1, Item 6

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All national bodies have the right to appeal in accordance with Clause 11 of JTC 1 Directives. In the present case, as P-member national body, it is not possible to exercise our right to appeal in reference to the content of the final text of the ISO 29500, as the same has not been made available to national bodies till date. Thus in terms of the provisions of 11.1.2 of JTC 1 Directives, there is a clear case for appeal.

We therefore request ISO to extend the permissible time period for the appeal providing sufficient time for examining the final text of the standard after the same has been made available to the national bodies.

Best Regards

(signature)

(Rakesh Kacker)
Director General, Bureau of Indian Standards

cc ISO/IEC JTC 1 Chairperson
ISO/IEC JTC 1 Secretariat

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FONDONORMA
Fondo para la Normalización
y Certificación de la Calidad

RIF:J000932670

Caracas, 30th May, 2008
Ref N° GN0080-08

Mr Alan Bryden
Secretary-General
Internacional Organization for Standardization ISO
CH-1211 Geneva 20
Switzerland
+ 41 22 733 34 30/ central(AT)iso.org

Appeal from the Venezuelan national body regarding the outcome of the fast-track processing of DIS 29500 Office Open XML.

The national body of Venezuela (FONDONORMA), as a P member of JTC 1, hereby submits an appeal against the outcome of the fast track processing of DIS 29500 Office open XML.

This appeal is made in accordance with Clause 11.1.2; "A P member of JCT 1 or an SC may appeal against any action, or inaction, on the part of JTC 1 or an SC when the P member considers that in such action or inaction:

* questions of principle are involved;

* the contents of a draft may be detrimental to the reputation of IEC or ISO; or

* the point giving rise to objection was not known to JTC 1 or SC during earlier discussions."

Reasons for appeal
1- In our opinion, the procedures used during the discussions of DIS 29500, including the Ballot Resolution Meeting held from 25 to 29 February 2008 are incompatibles with basic principles to the standardization, such as consensus, technically oriented discussions and redundancy of standards, among others.Attachment 1, Item 10

2- It is also our opinion that the proposed standard produced trough this procedures may be detrimental to the reputation of IEC or ISO as an standardization body, because of the clear absence of guidelines for the presentation of ISO standards. Attachment 1, Item 8

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3- We believe that the use of the fast track procedures was inadequate to the length and technical complexity of the DIS 29500 proposal, which added to the lack of technical, objective discussion, and the fact that procedures used during the Ballot Resolution Meeting held from 25 to 29 February 2008 leaved unattended too many standing technical issues in the proposal, resulted in a standard proposal that lacks the quality that usually describes the body of work of ISO. Attachment 1, Item 9

4- We also raise to your consideration the fact that up to date of writing, neither the final report of the BRM meeting or the revised FDIS text has been circulated by the SC Secretariat, in clear contradiction with clause 13.12, last bullet point: "In not more than one month after the ballot resolution group meeting the SC Secretariat shall distribute the final report of the meeting and fnal DIS text in case of acceptance." Attachment 1, Items 5, 6
Conclusion

Venezuela challenges the validity of a process that, from beginning to end, required all parties involved to analyze far too much information in far too little time, involved a BRM that by far did not provide enough time to perform the appointed purpose of that procedure, and for which an arbitrary time limitation was imposed to discuss and resolve a significant number of substantial responses, despite the Directives for not requiring any such [l]imitation as to duration.

The result of DIS 29500 has harmed the reputations of both ISO and the IEC, as well as all they member bodies, and has generated a terrible precedent in which the interest of large multi-national organization, both in favor or against an specific proposal, may dominate the debate instead of the technical discussions necessary to produce the optimal solution on every specific problem.

Best regards

Maria Teresa Saccucci
Standardization Manager
FONDONORMA
Venezuela

cc ISO TMB Secretary (Mr Mike Smith)
IEC SMB Secretary (Mr Jack Sheldon)
ISO/IEC JTC 1 Chairman (Mr Scott Jameson scott.jameson (AT) hp.com)
ISO/IEC JTC 1 Secretariat (Ms Lisa Rajchel lrajchel (AT) ansi.org)

[Fax]

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Example of letter sent to all appellants

Mr. Ricardo Fragoso
General Director
Associação Brasileira de Normas Técnicas
Av. 13 de Maio, n° 13, 28° andar
20031-901 – RIO DE JANEIRO-RJ
Brésil

Appeal concerning the approval of ISO/IEC DIS 29500 (OOXML)

Dear Mr. Fragoso,

We refer to the e-mail from Ms. Cristina de Oliveira dated 29 May 2008 by which ABNT submits an appeal against the decision to approve ISO/IEC DIS 29500 for publication as an International Standard.

In accordance with the Procedures for the technical work of ISO/IEC JTC 1 on information technology, the appeal needs to be submitted within one month to the ISO Technical Management Board and IEC Standardization Management Board for decision as to whether the appeal will be further processed or not.

However, in order to ensure that complete information is submitted to the management boards, we would draw your attention to subclause 11.1.4 of the JTC 1 Procedures which requires that appellants indicate the specific remedial action(s) that would statisfy the appellant's concerns. As it is not clear from your letter what remedial actions you are requesting, we should be grateful if you could provide us with this additional information within the next two weeks, that is by no later than 25th June 2008.

Yours sincerely,

[signature]
Aharon Amit
IEC General Secretary & CEO

[signature]
Alan Bryden
ISO Secretary-General

14987910

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Diretor Geral
Rua Minas Gerais n° 190 - Higienópolis
01244-010 - São Paulo - SP
Telefone (0xx) (11) - 3017.3618
Fax (0xx) (11) - 3017.3633
e-mail.: mmariotti(AT)abnt.org.br

DG-092/08


São Paulo, June-24-2008.


Mr. Aharon Amit
IEC General Secretary & CEO

Mr. Alan Bryden
ISO Secretary-General


Dear Mr. Amit and Mr. Bryden,


In attention to the request about the ABNT appeal concerning the approval of ISO/IEC DIS 29500 (OOXML), the remedial action that would satisfy ABNT concerns is:

Cancel the current process and return the subject to the NWIP stage following a regular process (not Fast-Track) by ISO/IEC/JTC1/SC34.”

This remedial action is based on three main reasons stated bellow:

1. About the decisions taken during the process

ABNT notes that during the ISO/IEC DIS 29500 Fast-Track Process, some decisions were taken in conflict with existing JTC1 Directives.

ISO/IEC/JTC1 Directive Sub-clause 13.1 states that:

“...In cases where the SC assignment is in question or where the fast-track document does not appear appropriate for any existing SC, the JTC 1 Secretariat may perform the duties normally assigned to the SC Secretariat until the final SC assignment is determined...”

ISO/IEC/JTC1 directly handled the ISO/IEC DIS 29500 Fast-Track Process from its beginning instead of ISO/IEC/JTC1/SC34 without any apparent reason.

ABNT considers that ISO/IEC/JTC1/SC34 was the appropriate SC to handle that process and we do not know any formal questioning about ISO/IEC/JTC1/SC34 capacity on handling it.

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ABNT also considers that this decision has placed Brazil on an unfavorable position, seeing that we are P members of ISO/IEC/JTC1/SC34 (and only “O” member of ISO/IEC/JTC1).

The criteria for acceptance of a Fast-Track proposal described on JTC1 Directive Sub-clause 13.2:

“13.2 The proposal for the fast-track procedure shall be received by the ITTF which shall take the following actions:

• Settle the copyright or trademark situation, or both, with the proposer, so that the proposed text can be freely copied and distributed within ISO/IEC without restriction;

• Assess in consultation with the JTC 1 Secretariat that JTC 1 is the competent committee for the subject covered in the proposed standard and ascertain that there is no evident contradiction with other ISO/IEC standards;

• Distribute the text of the proposed standard (or amendment) as a DIS (or DAM), indicating that the standard belongs in the domain of JTC 1 (see Form G12). In case of particularly bulky documents the ITTF may demand the necessary number of copies from the proposer.”

ABNT thinks that the second criteria was not meet by ISO/IEC DIS 29500 Fast-Track proposal because we consider that there is an evident contradiction with other existing ISO/IEC standards.

Those contradictions were even reported by several countries, following the procedures described by ISO/IEC/JTC1 Directive Sub-clause 13.4, but those reports seem to be ignored by ISO/IEC/JTC1.

The ISO/IEC/JTC1 Directive Sub-clause 13.4 states that:

“… During the 30-day review period, an NB may identify to the JTC 1 Secretariat any perceived contradiction with other JTC 1, ISO or IEC standards.

If such a contradiction is alleged, the matter shall be resolved by the ITTF and JTC 1 Secretariat in accordance with Section 13.2 before ballot voting can commence…”

ABNT understands that the contradictions should be resolved prior to the start of the 5 month ballot. The contradictions presented by several NB’s were answered by ECMA and most of those answers only proposed a discussion during the 5 month ballot. ISO/IEC/JTC1 then decided to start the 5 month ballot without solving the contradictions.

At the end of the whole ISO/IEC DIS 29500 Fast-Track Process, we found that some contradictions were not discussed at all. Attachment 2, Item 11

2. About the BRM

At the BRM, the Brazilian delegation was not allowed to present an important proposal regarding the legacy binary mapping. This proposal was a complementary part of USA delegation proposal regarding the new organization of the ISO/IEC DIS 29500. It also shall complement the scope change proposal approved at the BRM.

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ABNT has tried to present this proposal, during the debates, on the first day of the meeting and, attending to a request made by the Convenor, ABNT has taken offline discussions with USA and other delegations and prepared its proposal to be presented on Friday, during USA proposal presentation.

On Friday, when USA ended their part of presentation and asked for ABNT to present
its part of it, the Convenor denied this opportunity to Brazilian delegation.

Several delegations have protested against that arbitrary decision, but those appeals were in vain and until the end of the BRM, the Brazilian delegation was not able to present its proposal. The main reason alleged by the Convenor was “lack of time”.

The proposal here mentioned, is the one available on the file “Br_Multipart_Proposal.ppt” available to all BRM members the ISO/IEC/JTC1/SC34 website at least since the fourth day of the meeting.

ABNT also noticed that most of the decisions taken during the BRM were based on the “lack of time” argument, and we think that this is completely incompatible with the kind of decisions that should be taken on that meeting.

During the BRM, some decisions was also taken based on the argument that “we need to give answers to journalists”, and we think that the media coverage of that meeting was not so important as the meeting results, to be used as a decision making criteria.

Even with the “lack of time” alleged, some members of ECMA delegation, and not members of any NB, was allowed to do half-hour speeches during the two first days of the meeting.

The voting rules of that meeting were not taken in accordance with ISO/IEC/JTC1 Directives Sub-clause 9.1.4. ABNT also notes that the ISO/IEC/DIS 29500 was voted under ISO/IEC/JTC1 but the BRM was organized by ISO/IEC/JTC1/SC34. Even if the Directives Sub-clause 9.1.4 was intended to be used, ABNT cannot understand if the P status considered should be the ISO/IEC/JTC1 or the ISO/IEC/JTC1/SC34 one.

ABNT also considers that if most part of the issues was to be decided by vote, without any kind of discussion allowed, the voting procedure shall be conducted using electronic tools, not demanding financial resources to send a 3 member delegation to Geneva just to fill a voting ballot.

About the same subject, ABNT considers that the elected “default voting criteria” was only elected because it was the “less bad” criteria that could be analyzed, and we do not consider that this voting decision represents the intent of the vast majority of BRM delegates. They went there to discuss the technical propositions.

Analyzing the document “SC 34 N 990 - EDITED NOTES OF THE MEETING”, on page 7, we have found the register of BR objection to the multi-part split decision but analyzing the document “SC 34 N 989 - RESOLUTIONS OF THE MEETING” we do not find that objection registered.

During the BRM, the delegations were asked to vote in batch for the rejection of a set of responses that was considered by the Convenor as “responses without any editing instructions”. Those responses are listed on the file “dis29500-nochange.txt”, available at the SC34 website during the BRM and, as far as Brazilian delegates remember, this set of responses was “rejected in block” as requested.

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When we analyze the documents N989 and N990 we do not see any reference to that decision and also at the ISO/IEC/JTC1/SC 34 document with title “Result of Proposed disposition of comments (SC 34 N 980)”, that presents a table with the status of each response, some of the “block rejected responses” appears as accepted (e.g. responses 3, 5, 10 and 11 among others).

To finalize our considerations about the BRM, analyzing the document N 989, we have found that the BRM can be summarized by:

Total of responses available for discussion: 102-100 %

7
Total of responses addressed at the BRM: 189-18,4 %
Total of responses decided by “default” vote: 838-81,6 %

We use the term “responses addressed at the BRM” above because the majority of those responses was decided by block vote without any discussion at the BRM.

For the above-mentioned reasons, ABNT considers that the ISO/IEC DIS 29500 BRM was inconclusive. Attachment 1, Item 4

3. About the final version of DIS 29500 text

According to the directive item 13.12, the final version of the ISO/IEC DIS 29500 shall be distributed on not more than one month after the end of the BRM.

The JTC1 Directive Sub-clause 13.12 states that:

“13.12 The time period for these different steps shall be:

  • A total of two months for the ITTF to send the results of the vote to the JTC 1
    Secretariat and to the SC Secretariat, and for the latter to distribute it to its NBs;
  • Not less than two and one-half months prior to the date of the ballot resolution
    group meeting for distribution of the voting results and any comments;
  • Not later than one month after the ballot resolution group meeting for
    distributions by the SC Secretariat of the final report and the final DIS text in
    case of acceptance.”

Seen that almost three months has passed after the end of BRM, without any final version of the text distributed or published, and based on ISO/IEC JTC1 Directive Sub-clause 13.12, ABNT request the distribution of ISO/IEC DIS 29500 final text. Attachment 1, Item 6

Yours sincerely,

Ricardo Rodrigues Fragoso
General Director

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SABS

24 June 2008

ISO / IEC Central Secretariats
Geneva
Switzerland

Dear Mr Amit and Mr Bryden

RE: APPEAL CONCERNING THE APPROVAL OF ISO / IEC DIS 29500 (OOXML)

Your letter of 11 June 2008 refers

Per your request, attached the relevant information indicating the specific remedial action/s that would satisfy our concerns.

Trusting that our request will entertain you favourable consideration.

Yours sincerely

[Signature]
MARTIN KUSCUS
President of SABS

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DIS 29500: Requested specific remedial actions – South Africa

In response to the request from ISO/MB and the IEC/SMB for the specification of remedial actions that would assist in alleviating the concerns of South Africa regarding the procedures followed during the fast-tracking of DIS 29500 Office Open XML, we would offer the following:

1. We realise that, at this stage, it is unlikely that the BRM could be re-convened until all outstanding issues have been discussed. However, we maintain that the discussion by experts of only 67 out of the 1027 responses to comments that the Project Editor proposed does not constitute a successful conclusion of the BRM, especially since virtually every response discussed during the BRM was modified. We therefore request that the process of editing DIS 29500 be put on hold and that the approximately 794 ECMA responses that were never specifically discussed and resolved by the BRM be circulated to member bodies for voting (only editorial comments being permitted), since we dispute the validity of the results of the "blanket" voting on Friday afternoon. Insufficient time was provided for this mammoth task of voting on the approximately 794 ECMA responses that were never discussed during the BRM. We feel that this was an ill-considered and hasty action based on a perceived pressure to obtain some result from the BRM that could be released to the press and defeats the goal of producing excellent standards. Attachment 2, Item 14
2. There were many discussions during the BRM regarding the scope and title of the draft. The purpose of DIS 29500 is stated as: "OpenXML was designed from the start to be capable of faithfully representing the pre-existing corpus of word-processing documents, presentations, and spreadsheets that are encoded in binary formats defined by Microsoft Corporation. The standardization process consisted of mirroring in XML the capabilities required to represent the existing corpus, extending them, providing detailed documentation, and enabling interoperability." In our view, this has not been done in the existing draft, and was not addressed by ECMA in the revised draft, so the usefulness of the draft to non-Microsoft suppliers is not clear. Unfortunately, extended discussion on this important topic was>consistently deferred until, on the last day, there was insufficient time for a full discussion. It was repeated many times during the BRM that the intention of DIS 29500 was to faithfully reproduce legacy Microsoft documents. This led to various discussions on which requirements related to "legacy" and whether requirements should be "deprecated" or there should be more clarity between "strict" and "transitional" issues. During this discussion an important issue raised by Brazil, regarding legacy binary mapping and part of the USA proposal for dividing the draft into parts, was continuously deferred until, late on Friday, it was rejected due to "lack of time" – to a chorus of objections throughout the room. However, since it is the stated intent of the draft to reproduce legacy Microsoft documents, and since Microsoft has, after the BRM, expressed its intention of also supporting ISO/IEC 26300 Open document format (see press release attached in annex 1), we request that the title of DIS 29500 be changed to "Converting legacy Microsoft documents to Office Open XML" in order to reflect the fact that it is only intended to convert such legacy documents and is not intended to conflict with ISO/IEC 26300. Attachment 2, Item 16
3. We support the initiatives started by JTC 1/SC 34 at its recent plenary meeting in Norway, being the establishment of two ad hoc groups to (a) collect comments regarding deficiencies in and (b) prepare a revision of the text of, ISO/IEC 29500. It is our opinion that there is no need to delay this work until the current draft text is published since, if the text of DIS 29500 that emanated from the BRM was of sufficient quality to release to the ITTF for editing, it is surely of adequate quality to release to SC 34, who have sufficient experience to correct the remaining technical errors. Ideally we would prefer to delay the publishing of DIS 29500 until SC 34 have been able to complete this work, but we realize the extent of the political pressure that might be applied to ISO and the IEC to expedite the publishing of this document regardless of technical deficiencies. We therefore request that SC 34 be instructed by JTC 1 to start a project without further delay for the amendment or revision of the text of DIS 29500, without waiting for the ITTF to publish the standard, and that the ITTF be requested to immediately release to SC 34 the existing text of DIS 29500, as resulting from the resolutions of the BRM. Attachment 1, Item 6
4. Regarding the issue of lack of clarity over, and discussion of, the contradictions raised by member bodies during the pre-DIS voting period, we contend that the ITTF and the JTC 1 Secretariat erred in their decision not to hold a meeting. We also contend that ECMA should have had no role in achieving this decision, other than to indicate whether they wished to

SA DIS 29500 appeal conciliation 2008/06/25 Page 1 of 5 (23)


withdraw the draft or continue with the fast track process. At a minimum, the alleged contradictions should have been circulated to all member bodies in order to ensure the transparency of the process. The expectation that national bodies would have repeated their alleged contradictions in their comments and that there was therefore no need to consider separately the issues raised during the review period was ill-founded. Any appeal by South Africa against such an omission after the ballot had been initiated would, in our opinion, have been pointless. The statement at the HoD meeting held just prior to the BRM clearly stated that any issues on contradictions that were raised during the BRM would be ruled out of order. This definitely created the impression that issues regarding conflicts between DIS 29500 and ISO/IEC 26300, or other standards, would not be permitted, regardless of whether or not they were included under member body comments. In fact, the information regarding alleged contradictions has still not been made available, and we request a modification to the Directives to ensure that in all cases any alleged contradictions are circulated to all member bodies before the start of the DIS balloting period and that any discretion for the ITTF or TC/SC Secretariats to deviate from the Directives in this fashion should be expressly forbidden. Attachment 1, Item 1
5. We request that the ISO/IEC Directives be modified to ensure that sufficient time is provided in any future BRM in order to avoid a repetition of such arbitrary limitations being placed on the technical experts who meet in order to agree on dispositions of comments. As an example from the DIS 29500 BRM, the discussion of 1027 responses in the allocated 40 hours implies discussing and achieving agreement at a rate of less than 2,5 minutes per response. Whoever arranged the BRM should have realised that this was not possible. Not germane
6. We are of the opinion that the intention of any BRM is that ALL of the assembled experts should be able to deliberate on ALL comments raised and reach consensus. Notwithstanding our comments on the arrangements of the BRM in 5, we feel that the instructions towards the closing stages of the BRM that member bodes should participate in a ballot regarding the responses that were never discussed was equivalent to "handing a blank cheque" to ECMA, since it only took a few countries to vote "Yes" to all responses to tip the scale towards acceptance of all the responses that were never discussed. That this occurred is evident from the voting results. We request a change to the Directives to ensure that all the changes to text in the proposed dispositions of comments submitted by the Project Editor be reviewed by the BRM. If, for some reason, the BRM is unable to review all proposals then all remaining proposals shall be resolved either by another BRM or by a second round of commenting and voting on the outstanding disposition proposals. Specifically, any "blanket" voting, such as that used to resolve the ECMA responses that were never discussed, shall not be permitted as a means of resolving proposed dispositions, except in the case of editorial corrections that have been accepted by the Project Editor. Attachment 1, Items 4, 10
7. We note the comment by ITTF that the final DIS text has not yet been made available to date (as required by clause 13.12) "simply because a text in a mature state for release does not exist". In response we simply repeat our comment that "given the magnitude of the specification and the number of identified edits required it was clear that this directive could not have been met. This is the clearest possible indication that DIS 29500 as submitted by ECMA was not ready for fast track balloting." We request urgent changes to the Directives to prevent such large and complex documents from being submitted for fast track balloting, especially if constrained by the normal time periods for DIS balloting. The intention of the fast track process is to permit standards that have met the test of use in the marketplace over a reasonable period of time to be easily adopted as JTC 1 standards. We support this intention of JTC 1 and would not like to see such a process removed due to what is, in our opinion, an error of judgement regarding DIS 29500. Not germane
8. The Directives and fast track procedures must be revised to prevent them from becoming a quick way of obtaining an "ISO" stamp on otherwise dubious or blatantly commercial "standards". We request that the current provision that liaison organisations have the right to submit documents for fast track ballot have some checks built in regarding international market relevance. The addition of a step requiring the experts on the relevant JTC 1 SC to review the document and recommend a course of action would assist in ensuring that the submitted document was recognised in the marketplace as being internationally relevant, and would assist the JTC 1 Secretariat and ITTF in reaching a decision regarding further processing. In this regard we add that we are concerned about the number of consortia and associations that

SA DIS 29500 appeal conciliation 2008/06/25 Page 2 of 5 (24)


are applying for liaison status with JTC 1 and then submitting their standards for acceptance as international standards. Although we do welcome their participation within JTC 1, it seems as if some are only driven by the desire for the ISO "stamp of approval" and do not thereafter participate actively in committee work. Not germane
9. One of the allegations that we feel has done considerable damage to the reputation of ISO, the IEC and, by association, to member bodies is that of "committee stuffing". We request the addition of requirements in the Directives of a threshold period of participation by member bodies before they be permitted to participate in fast track ballots. This threshold should also include limitations on changing of participation status. We do not propose limitations on applications for participation or change of status, but only on the right to vote on fast track projects. We appreciate that ISO or the IEC is not able to control issues within the member body's technical committees, but the sudden increase in member bodies that participated in the JTC 1 ballot on DIS 29500 is not a fair reflection on those who had previously shown their commitment by regular participation in the work of JTC 1 and its sub-committees. Not germane
10. The South African comments submitted that were never discussed at the BRM due to "lack of time" included concerns regarding the weak hashing algorithm used for password protection of documents and how this was to be handled during conversion of legacy documents. However, South Africa undertakes to address its remaining concerns with the requirements in DIS 29500 by participating in the SC 34 work in order to reconcile DIS 29500 with existing ISO/IEC, W3C and other standards. Ideally, we would prefer the eventual integration of this document with the existing ISO/IEC 26300 standard so that there is truly a single XML standard for office documents, with possibly a part dealing with the conversion of Microsoft's legacy documents. Not germane

Conclusion

We include a short summary of our specific requests for consideration at the conciliation panel meeting, as follows:

1. We request that the process of editing DIS 29500 be put on hold and that the approximately 794 ECMA responses that were never specifically discussed and resolved by the BRM be circulated to member bodies for voting (only editorial comments being permitted).
2. We request that the title of DIS 29500 be changed to "Converting legacy Microsoft documents to Office Open XML" in order to reflect the fact that it is only intended to convert such legacy documents and is not intended to conflict with ISO/IEC 26300, since the purpose of DIS 29500 is clearly stated: "OpenXML was designed from the start to be capable of faithfully representing the pre-existing corpus of word-processing documents, presentations, and spreadsheets that are encoded in binary formats defined by Microsoft Corporation. The standardization process consisted of mirroring in XML the capabilities required to represent the existing corpus, extending them, providing detailed documentation, and enabling interoperability."
3. We request that SC 34 be instructed by JTC 1 to start a project without further delay for the amendment or revision of the text of DIS 29500, without waiting for the ITTF to publish the standard, and that the ITTF be requested to immediately release to SC 34 the existing text of DIS 29500, as resulting from the resolutions of the BRM.
4. We request a modification to the Directives to ensure that in all cases any alleged contradictions are circulated to all member bodies before the start of the fast track DIS balloting period and that any discretion for the ITTF or TC/SC Secretariats to deviate from the Directives in this fashion should be expressly forbidden.
5. We request that the ISO/IEC Directives be modified to ensure that sufficient time is provided in any future BRM in order to prevent arbitrary limitations being placed on the technical experts who meet in order to agree on dispositions of comments.
6. We request a change to the Directives to ensure that all the changes to text in the proposed dispositions of comments submitted by the Project Editor be reviewed by the BRM. If, for some reason, the BRM is unable to review all proposals then all remaining proposals shall be resolved either by another BRM or by a second round of commenting and voting on the

SA DIS 29500 appeal conciliation 2008/06/25 Page 3 of 5 (25)


outstanding disposition proposals. Specifically, any "blanket" voting, such as that used to resolve the ECMA responses that were never discussed, shall not be permitted as a means of resolving proposed dispositions, except in the case of editorial corrections that have been accepted by the Project Editor.
7. We request urgent changes to the Directives to prevent such large and complex documents from being submitted for fast track balloting, especially if constrained by the normal time periods for DIS balloting.
8. We request that the current provision that liaison organisations have the right to submit documents for fast track ballot have some checks built in regarding international market relevance.
9. We request the addition of requirements in the Directives for a threshold period of participation by member bodies before they be permitted to participate in fast track ballots. This threshold should also include limitations on changing of participation status. We do not propose limitations on applications for participation or change of status, but only on the right to vote on fast track projects.
10. South Africa undertakes to address its remaining concerns with the requirements in DIS 29500 by participating in the SC 34 work in order to reconcile DIS 29500 with existing ISO/IEC, W3C and other standards. Ideally, we would prefer the eventual integration of this document with the existing ISO/IEC 26300 standard.

SA DIS 29500 appeal conciliation 2008/06/25 Page 4 of 5 (26)

Annex 1

PRESS RELEASE

REDMOND, Wash. — May 21, 2008 — Microsoft Corp. is offering customers greater choice and more flexibility among document formats, as well as creating additional opportunities for developer and competitors, by expanding the range of document formats supported in its flagship Office productivity suite.

The 2007 Microsoft Office system already provides support for 20 different document formats within Microsoft Office Word, Office Excel and Office PowerPoint. With the release of Microsoft Office 2007 Service Pack 2 (SP2) scheduled for the first half of 2009, the list will grow to include support for XML Paper Specification (XPS), Portable Document Format (PDF) 1.5, PDF/A and Open Document Format (ODF) v1.1.

When using SP2, customers will be able to open, edit and save documents using ODF and save documents into the XPS and PDF fixed formats from directly within the application without having to install any other code. It will also allow customers to set ODF as the default file format for Office 2007. To also provide ODF support for users of earlier versions of Microsoft Office (Office XP and Office 2003), Microsoft will continue to collaborate with the open source community in the ongoing development of the Open XML-ODF translator project on SourceForge.net.

SA DIS 29500 appeal conciliation 2008/06/25 Page 5 of 5 (27)

Caracas, 23rd June, 2008
Ref. Nº: DG0015/2008

Mr. Alan Bryden
Secretary-General
International Organization for Standardization (ISO)
1 Chemin de la Voie-Creuse
Case postale 56
CH – 1211 Genéve 20
Switzerland

Dear Mr. Bryden,

Appeal concernin the approval of ISO/IEC 29500 (OOXML) –
Request for specific remedial actions

Request for specific remedial actions from the Venezuelan national body regarding the appeal of the outcome of the fast-track processing of DIS 29500 Office Open XML.

The national body of Venezuela (FONDONORMA), as a P member of JTC 1, hereby submits a request for specific remedial actions of the issues raised on the appeal submitted to ISO/IEC on 05/30/2008, in accordance with Clauses 11.1.2 and 11.1.4 of the JTC1 Procedures.

Reasons for appeal and remedial action requested:

1- In our opinion, the procedures used during the discussions of DIS 29500, including the Ballot Resolution Meeting held from 25 to 29 February 2008 are incompatibles with basic principles to the standardization, such as consensus, technically oriented discussions and redundancy of standards, among others. Attachment 1, Item 10

Remedial actions requested:

1.a- Change the title of DIS 29500 to "Converting legacy Microsoft documents to Office Open XML" in order to reflect the fact that it is only intended to convert such legacy documents and is not intended to conflict with ISO/IEC 26300. This change should be made to the scope of the DIS as well. Attachment 2, Item 16

1.b- Adjust the guidelines of the JTC1 in order to clearly state how to handle the alleged contradictions that may arise between new standards proposals and the existing body of work. We recommend that any DIS or PAS with alleged contradictions shouldn't be discussed trough the Fast Track process. Not germane

1.c- Adjust the guidelines of the JTC1 to avoid the use of the Fast Track Process to discuss proposal that has no generalized implementations in the industry, or with a high level of conflict in the industry. Not germane

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1.d- Adjust the guidelines of the JTC1, to increase the transparency in the conformation of the SC. We believe that avoiding any further comments about “Committee-stuffing“ is a necessity in order to keep a high reputation of ISO, IEC and the National Bodies as standardization organizations, and we think that strong actions are needed to prevent suspicious situations that affected the DIS 29500 process. We recommend that the guidelines should encourage the conformation of heterogeneous SC, and that any representation of a collective or an organization in a SC should be backed by a written document that clearly states the right of representation. Not germane

2- It is also our opinion that the proposed standard produced trough this procedures may be detrimental to the reputation of IEC or ISO as an standardization body, because of the clear absence of guidelines for the presentation of ISO standards. Attachment 1, Items 8, 10

Remedial actions requested:

2.a- Publicize the post-BRM DIS 29500, which at the time of writing is more than two months due, as a Committee Draft and reprocess it trough the regular procedures of discussion, in order to generate a new DIS that comply with the guidelines for the presentation of ISO standards and with a quality similar to the Body of Work or ISO and IEC. Attachment 1, Item 6

3- We believe that the use of the fast track procedures was inadequate to the length and technical complexity of the DIS 29500 proposal, which added to the lack of technical, objective discussion, and the fact that procedures used during the Ballot Resolution Meeting held from 25 to 29 February 2008 leaved unattended too many standing technical issues in the proposal, resulted in a standard proposal that lacks the quality that usually describes the body of work of ISO. Attachment 1, Items 4, 9

Remedial actions requested:

3.a- Adjust the guidelines of the JTC1, to avoid the use of the Fast-Track Process to discuss proposals with a high level of complexity or with a large body of proposal. The size and complexity of the proposal affects the quality of the technical discussion when the time available to analyze it is constrained, and also affects the conformation of the Committees, because limits the participation of non- compromised, objective experts in favor of paid experts with compromised positions. Not germane

3.b- Adjust the guidelines of the JTC1 to guarantee that all the standing issues are discussed by the assembled experts on a BRM. Special emphasis should be made to avoid the group-voting of standing issues when there is opposition of any assembled member. (see BRM vote breakdown table in annex 1). Not germane

3.c- Publicize the post-BRM DIS 29500, which at the time of writing is more than two months due, as a Committee Draft and reprocess it trough the regular procedures of

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discussion, in order to generate a new DIS with no technical standing issues (see attached annex 2) Not germane

4- We also raise to your consideration the fact that, up to date of writing, neither the final report of the BRM meeting or the revised FDIS text has been circulated by the SC Secretariat, in clear contradiction with clause 13.12, last bullet point: "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." Attachment 1, Items 5, 6

Remedial actions requested:

4.a- The fact that the final, post-BRM DIS 29500 is not public even after two months of the BRM is a clear indication that DIS 29500 is not ready for publishing as an International Standard, so we request to stop the publication of DIS 29500 and to reprocess it trough the regular procedures of discussion and balloting.

Conclusion

Venezuela challenges the validity of a process that, from beginning to end, required all parties involved to analyze far too much information in far too little time, involved a BRM that by far did not provide enough time to perform the appointed purpose of that procedure, and for which an arbitrary time limitation was imposed to discuss and resolve a significant number of substantial responses, despite the Directives for not requiring any such limitation as to duration.

The result of DIS 29500 has harmed the reputations of both ISO and the IEC, as well as all they member bodies, and has generated a terrible precedent in which the interest of large multi-national organization, both in favor or against an specific proposal, may dominate the debate instead of the technical discussions necessary to produce the optimal solution on every specific problem.

We hereby request to cancel the publishing of DIS 29500 as an International Standard, reprocess it trough the regular procedures of discussion and balloting, and adjusting the JTC1 guidelines in order to avoid the problems described above.

Yours sincerely,

Norma Arias
Director-General

Enclosures

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Annex 1 – BRM Vote Breakdown Table

Total of responses available for
discussion
Total of responses addressed at
the BRM
Total of responses decided by
group-voting
1027 - 100% 189 – 18,4% 838 – 81,6 %

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Annex 2 – Standing Issues as presented by VE

NB/MB
Comment
BRM
Question
Number
Covered in
BRM?
Appropiately Addressed?
VE-0001 102 YES NO. The mechanisms persist in an annex when they
should be entirely removed. Also, the use of MD2 and
MD4 (weak cryptographic algorithms) is suggested.
VE-0002 142 NO NO. The use of BLOBs (Binary Large Objects) is
mantained, without specifying mechanisms for
retrieving/displaying them and also leaving the
implementation up to the developer without any
specifications.
VE-0007 0073 NO NO. Pseudo-code is not specified in the standard. This
was not addressed at the BRM
VE-0008 0035 NO NO. Complex configurations are moved and rewritten in
an annex and the necessary documentation has not been
delivered.
VE-0009 0035 NO NO. Complex configurations are moved and rewritten in
an annex and the necessary documentation has not been
delivered.
VE-0010
YES YES
VE-0011 0018 NO NO. The changes made at the BRM keep the old style
date format as the default. 1900 should not be handled as
a leap year.
VE-0012 0035 NO NO. Complex configurations are moved and rewritten in
an annex and the necessary documentation has not been
delivered.

VE-0013 0092 YES NO. New XML types are defined as to eliminate VML,
however, there's no text that explains the new XML
types or their meaning. VML is moved to an annex when
it should be entirely removed.
VE-0014 0092 YES NO. New XML types are defined as to eliminate VML,
however, there's no text that explains the new XML
types or their meaning. VML is moved to an annex when
it should be entirely removed.
VE-0015
YES YES
VE-0016 0101
(related)
NO NO. All the render parameters are left to the application
side implementation.
VE-0017 102 YES NO. The mechanisms persist in an annex when they

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should be entirely removed. Also, the use of MD2 and
MD4 (weak cryptographic algorithms) is suggested.
VE-0018
YES YES
VE-0019
YES YES
VE-0020
YES YES
VE-0021 0099 YES NO. Partially addressed. Proposes a dual mode solution,
when it should propose a universal solution.
VE-0022
YES YES
VE-0023 0099 YES NO. Partially addressed. Proposes a dual mode solution,
when it should propose a universal solution.
VE-0024
YES YES
VE-0025
YES YES
VE-0026
NO NO. Ecma claims that this is against the proposal
objectives.
VE-0027
YES YES
VE-0028
NO NO. Ecma claims that this is against the proposal
objectives.
VE-0029
NO NO. Ecma does not understand the observation.
VE-0030
YES YES
VE-0031 0232
(related)
NO NO. Ecma claims that DIS 29500 is compatible with
SVG, but errors occur when the reference
implementation is replicated.
VE-0032
YES YES
VE-0033
YES YES
VE-0034
YES YES
VE-0035 0016 YES NO. The proposed solution partially changes the text that
defines ST_LangCode and keeps the same underlying
failure of having two ways of identifiying languages
instead of using ISO 639
VE-0036 0016 YES NO. The proposed solution partially changes the text that
defines ST_LangCode and keeps the same underlying
failure of having two ways of identifiying languages
instead of using ISO 639
VE-0037
YES YES
VE-0038 0016 YES NO. The proposed solution partially changes the text that
defines ST_LangCode and keeps the same underlying
failure of having two ways of identifiying languages
instead of using ISO 639
VE-0039
YES YES

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VE-0040
YES YES
VE-0041
YES YES
VE-0042
NO NO. The XSLT standart is allowed as a customization
and it's not default.
VE-0043
YES YES
VE-0044
YES YES
VE-0045
YES YES
VE-0046
YES YES
VE-0047
YES YES
VE-0048
YES YES
VE-0049
YES YES
VE-0050
YES YES. Comment: OOXML uses a custom type to store
content that goes against the XML standard.
VE-0051
YES YES
VE-0052
YES YES
VE-0053
YES YES. Comment: OOXML uses a custom type to store
content that goes against the XML standard.
VE-0054 102 YES NO. The mechanisms persist in an annex when they
should be entirely removed. Also, the use of MD2 and
MD4 (weak cryptographic algorithms) is suggested.
VE-0055 102 YES NO. The mechanisms persist in an annex when they
should be entirely removed. Also, the use of MD2 and
MD4 (weak cryptographic algorithms) is suggested.
VE-0056 102 YES NO. The mechanisms persist in an annex when they
should be entirely removed. Also, the use of MD2 and
MD4 (weak cryptographic algorithms) is suggested.
VE-0057 0341 NO NO. The paper size is stored as a code instead of using
an standard format
VE-0058 0341 NO NO. The paper size is stored as a code instead of using
an standard format
VE-0059
YES YES
VE-0060 0018 NO NO. The changes made at the BRM keep the old style
date format as the default. 1900 should not be handled as
a leap year.
VE-0061
YES YES
VE-0062
YES YES
VE-0063
YES YES
VE-0064
YES YES

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VE-0065
YES YES
VE-0066
YES YES
VE-0067
YES YES
VE-0068
NO NO. These foreign XML entities are kept, despite the
compatibility issues.
VE-0069
YES YES
VE-0070
YES YES. Comment: The technical issues specified by the
National Body do not represent all the interoperativity
problems between operating systems of this proposal. A
big vendor dependency issue persists and the lack of
practical implementations for multiple environments.
VE-0071
YES YES. Comment: The technical issues specified by the
National Body do not represent all the interoperativity
problems between operating systems of this proposal. A
big vendor dependency issue persists and the lack of
practical implementations for multiple environments.
VE-0072
YES YES. Comment: The technical issues specified by the
National Body do not represent all the interoperativity
problems between operating systems of this proposal. A
big vendor dependency issue persists and the lack of
practical implementations for multiple environments.
VE-0073 0092 YES NO. New XML types are defined as to eliminate VML,
however, there's no text that explains the new XML
types or their meaning. VML is moved to an annex when
it should be entirely removed.

(35)


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