On Fri, May 23, 2008 at 8:42 PM, Allen Brown <[EMAIL PROTECTED]> wrote:
> It's tough reading.  I can only read a few minutes at a time
> before my eyes glaze over.  And I haven't finished.  But I
> don't think I will be able to consider the big picture when
> I do finish, because of the aforementioned glazing.

I'm assuming the glazing is largely due to phrasing and fairly arcane
subject matter with its own unique vocabulary -- the overlap of law
and a specialized area of technology -- rather than typography.  But I
would appreciate any clues  you might contribute on how to lessen that
problem. I am aware that the Dupal theme I'm using formats footnotes
in small type size and am working toward improving that. (I've found a
theme more suitable for customization.)

I'm aiming toward both something like what you're looking at and a
condensed version that omits the commentary. (I realize that the
commentary will put a lot of people to sleep.) At the same time, it's
necessary in creating a document that has a prayer of withstanding a
concerted legal challenge to use precise terminology and to be
sufficiently detailed to avoid ambiguity that could lead to different
interpretations. Condensing is part of the polishing process and I
have a fair distance to go in that department.

> I think the problem of determining whether a program or dataset
> is conforming is difficult, and I don't know if you defined this.

It is not defined as such, but legally defensible tests are framed by
the clause in paragraph 10 requiring specification of, "conformity
requirements essential to achieve interoperability" and in paragraph
11 by "fully specified conformity assessment procedures adequate to
ensure interoperability."

It's difficult to go much beyond establshing the legal tests in this
area because the methodology necessary for conformity assessment in
regard to a particular specification is variable. I agree
wholeheartedly that conformity assessment is not a simple process.

> But it seems to me that in a practical sense only a parser
> can say if a dataset is conforming.  How would you address
> this?

As to the specific language of the text, right now I'm inclined not to
go much beyond what is already said in the body, although I may add
some information in the corresponding notes.

Back in the real world, parsing and comparison to a reference is about
as far as you can go in terms of real-time on-the-fly data set
validation. In XML markup languages, validation against the grammar
specified by a reference schema or DTD is the normal method. See
<http://en.wikipedia.org/wiki/XML_schema>.

But many IT standards have normative requirements that cannot be
parsed, e.g., data presentation aspects. Commonly used conformance
assessment methods for presentation aspects include creation or
designation of a reference implementing application or creation of
test suites. Under the reference application approach, developers can
compare their implementations' output to that of the reference
application, using a standard battery of data sets.

Test suites normally establish reference displays of how particular
small data sets should appear visually when rendered. The small data
sets and their reference displays are commonly developed concurrently
with a standard's development and implementation, allowing
implementing developers to to compare results as they go, renegotiate
normative requirements as necessary, etc.

There's a good example of a test suite in active development and use
here. <http://www.w3.org/2004/CDF/TestSuite/WICD_CDR_WP1/wicdmatrix.xhtml>.
It's the test suite for the WICD profiles for creating W3C Compound
Document Formats. The link is to the summary matrix, showing the
conformance/implementation state of several participating browser
developers' implementations. If you click on the links in the column
to the left of the visible table, you'll be taken to the text of the
relevant normative requirement, and beneath the text of each normative
requirement, there is a link to the test for that requirement.

The test displays one or more graphic images or formatted text, a
written description of what you should be seeing, and a link to a
screenshot of what you should be seeing. If what the developer sees is
what s/he is supposed to see, then the browser has passed that test.
The matrix lets everyone see what how far along everyone is in
implementation and conformance.

There are similar test suites around for other data types, of course,
e.g., audio and video.  But generally speaking, what the conformity
assessment procedure is largely depends on what the relevant normative
requirement is. I.e., if it's not presentation but a different aspect
of implementation, then a different kind of procedure will be
necessary. E.g., if you are dealing with a standard for spreadsheet
formulas, then the assessment procedure might call for entering
particular data and to arrive at a specified mathematical result.

I don't think I'm pushing the envelope too far with the legal tests
I've boiled down in regard to conformity assessment procedures..
ISO/IEC JTC 1 Directives, which govern the preparation of
international standards in the IT sector, require:

"It is the responsibility of each JTC 1 Subcommittee to ensure that
any conformity requirements in its standards or ISPs for
implementation in products are unambiguous and that conformity to
those requirements is verifiable.
...

"A conformity assessment methodology may include the specification of
some or all of the following: terminology, basic concepts,
requirements and guidance concerning test methods, test specification
and means of testing, and requirements and guidance concerning the
operation of conformity assessment services and the presentation of
results.
...

"This policy statement specifies the JTC 1 position on
interoperability and clarifies the relationship between
interoperability and conformity. ... For the purpose of this policy
statement, interoperability is understood to be the ability of two or
more IT systems to exchange information at one or more standardised
interfaces and to make mutual use of the information that has been
exchanged. An IT system is a set of IT resources providing services at
one or more interfaces.
...

"Standards designed to facilitate interoperability need to specify
clearly and unambiguously the conformity requirements that are
essential to achieve the interoperability. Complexity and the number
of options should be kept to a minimum and the implementability of the
standards should be demonstrable. Verification of conformity to those
standards should then give a high degree of confidence in the
interoperability of IT systems using those standards. However, the
confidence in interoperability given by conformity to one or more
standards is not always sufficient and there may be need to use an
interoperability assessment methodology in demonstrating
interoperability between two or more IT systems in practice.

"An assessment methodology for interoperability may include the
specification of some or all of the following: terminology, basic
concepts, requirements and guidance concerning test methods, the
appropriate depth of testing, test specification and means of testing,
and requirements and guidance concerning the operation of assessment
services and the presentation of results. In technical areas where
there is a conformity assessment methodology and an interoperability
assessment methodology, the relationship between them must be
specified."

It all sounds great, but It's routinely ignored in an era when the
international standards for IT development scene has been captured by
big vendors. I'm trying to take a rather huge body of international
law, antitrust law, and case decision precedents involving
interoperability and accessibility down to fundamental principles, a
set of criteria that eGovernment and government procurement folk,
including their lawyers can use as a meta-standard for evaluation and
selection of IT standards. E.g., just the European Community Court of
First Instance decision in the Microsoft case last September runs
nearly 1,400 paragraphs.

As nearly as I can tell there are no published efforts to summarize
the law governing interoperability and accessibility in standards
work, which is scattered from here to Kingdom Come. I believe
fervently that universal interoperability and accessibility must of
necessity be the glue points in the software infrastructure of the
Information Society unless we are aiming for such a society only for
the wealthy.

Since no one else had summarized the law in this area, I decided it
was a worthy task. It may take very many more drafts  to achieve a
stable release. But I'm sensitive to the fact that universal
interoperability and accessibility can bring about economic growth in
developing nations that can dramatically improve health care, tackle
the starvation problem, and raise much of humanity from other shackles
of poverty. So I'm highly motivated to get this document right and
really appreciate any feedback.

Thank you for the helpful criticism,

Marbux.
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