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Saturday, January 20, 2007

Gary W. Kushnier - Vice President, International Policy
American National Standards Institute

1819 L Street, NW, 6th Fl.
Washington, DC, 20036

fax: 202.293.9287


Mr. Kushnier:

I am writing you today to ask the ANSI, in its role as the American representative to the International Standards Organization, to oppose the adoption of the Microsoft-proposed Open XML document format ("OOXML") as an ISO Standard.

The adoption of OOXML as an ISO Standard does not serve the public interest. The format specification has many flaws that prevent it from being suitable or desirable as an international Standard for interoperability. Among those flaws are:

  1. OOXML does not conform to existing ISO Standards, and in fact requires behavior in conflict with those standards:

  2. OOXML requires support of Microsoft-proprietary formats (e.g. for Windows Metafile and Windows Enhanced Metafile for images) that are intimately bound to the specific APIs and behavior of Microsoft Windows.

  3. OOXML specifies compliance with the behaviors and misbehaviors of obsolete and increasingly difficult-to-obtain versions of proprietary document processing utilities from Microsoft and other vendors. These behaviors are only specified by reference, for example, "applications shall emulate the behavior of a previously existing word processing application (Microsoft Word 6.x/95/97) when determining the placement of the contents of footnotes".

    These behaviors cannot be properly implemented without access to the software in question (which can only get more difficult as time passes) or by contacting the vendor (if the vendor still exists) and asking for access to internal information proprietary to that vendor (if they are willing to share). Furthermore, some if not all of these behaviors are covered by licensing agreements that prohibit reverse engineering.

    This is not what an international Standard promoting interoperability should require of a software developer.

  4. OOXML requires implementation of capabilities that are apparently not covered by Microsoft's patent pledge, so support for the OOXML format apparently cannot be fully implemented without a licensing agreement with Microsoft (which they are under no obligation to provide). This appears to be in violation of § 2.14 of the ISO/IEC Directives, Part 1. OOXML should not be considered for adoption as a Standard until this matter is resolved.

  5. The OOXML specification document is over 6,000 pages long, and incorporates many proprietary behaviors and proprietary ancillary file formats by reference. Implementing most if not all of these behaviors would require the cooperation of Microsoft. It is doubtful that anyone other than Microsoft will ever be able to correctly implement the OOXML specification. This is not how interoperability is encouraged or achieved.

The OOXML specification duplicates the features provided in an existing ISO Standard (ISO/IEC 26300:2006 Open Document Format for Office Applications (OpenDocument) v1.0) and provides no real benefit other than to protect the existing market of a single vendor. This is not what Standards are for.

If the ISO (and by extension the ANSI) adopts such a specification as a Standard, their reputations will be severely damaged. They will be seen as open to manipulation and control by sufficiently large companies, and it sets the precedent for corruption of the standards process in order to protect market share to the detriment of competition, interoperability and the end user.

The ISO and the ANSI trade on their reputations of impartiality. Do not support the adoption of OOXML as an ISO Standard -- only one company would benefit at the expense of all others.

Thank you for your consideration.






John Hardin




Lisa Rajchel - Director, International Secretariats Standards Facilitation
fax: 212.840.2298

Steven P. Cornish - Program Director, International Policy
fax: 212.730.1346

Henrietta Scully - Program Manager, Standards Facilitation (ISOT)
fax: 212.730.1346