Paul, thanks for your review. I have cc’ed you on my DISCUSS ballot.

Best,
Alissa


> On Feb 18, 2020, at 1:29 PM, Paul Kyzivat <pkyzi...@alum.mit.edu> wrote:
> 
> I am the assigned Gen-ART reviewer for this draft. The General Area Review 
> Team (Gen-ART) reviews all IETF documents being processed by the IESG for the 
> IETF Chair. Please wait for direction from your document shepherd or AD 
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> 
> Document: draft-spinosa-urn-lex-13
> Reviewer: Paul Kyzivat
> Review Date: 2020-02-18
> IETF LC End Date: 2017-09-14
> IESG Telechat date: 2020-02-18
> 
> Summary:
> 
> This draft is on the right track but has open issues, described in the review.
> 
> General:
> 
> I did a Last Call review on version -11 three years ago. Given the amount of 
> time that has passed, and the extent of changes, I'm surprised that there 
> wasn't another Last Call prior to scheduling the Telechat!
> 
> I had difficulty classifying the severity of the issues. Individually most of 
> them may be minor, but in aggregate they imply that IMO the document still 
> requires a lot of work.
> 
> Issues:
> 
> Major: 1
> Minor: 15
> Nits:  2
> 
> 1) MAJOR: Structure & ordering of the document
> 
> In spite of my earlier experience with this document I found it very 
> difficult to read in a single front to back pass. In retrospect, I think it 
> would have made much more sense if I had read Section 7 first.
> 
> A major problem was that I got the impression it was a goal that an arbitrary 
> legal document reader should be able to construct a valid LEX URN to that 
> document from information readily available to him, typically in the body of 
> the document itself. Yet I found many places where terms must be chosen in 
> ways that are not deterministic.
> 
> In retrospect, especially after reading Section 7, I tentatively reached the 
> conclusion that my first impression was wrong. Instead, it appears that an 
> expert (probably within the Jurisdiction Registrar) must choose the LEX URN 
> representation(s) for the legal document. This can then be incorporated into 
> the document and/or some metadata about the document that is potentially 
> available to those who later have need to reference the document.
> 
> I'm not sure I'm right about this. How this is intended to work should be 
> spelled out early in the document. I suggest moving Section 7 early in the 
> document, and elaborating it to cover this.
> 
> Section 3 (Registration Template) is very hard to follow when reading the 
> document front to back. Understanding it requires information that hasn't yet 
> been provided. In particular, section 3.1 gives an overview of the syntax of 
> 'jurisdiction', but not for 'local-name'. It then goes on to present examples 
> of full lex URNs.
> 
> I suggest that it would be helpful to move sections 2 and 3 to a position 
> later in the document - somewhere after section 5. Near or in Section 11 
> (IANA considerations) would be a good place.
> 
> 2) MINOR(?): Encoding national characters and diacritic signs
> 
> Section 4.4 has guidelines for encoding national characters and diacritic 
> signs for compatibility with DNS. I'm not qualified to evaluate whether these 
> guidelines are in agreement with best practice for DNS. If it hasn't already, 
> this document should be reviewed and approved by relevant experts.
> 
> 3) MINOR: Section 5 (Specific Syntax and Features of the LEX Identifier):
> 
> It isn't clear to me what specific components of the syntax are being 
> addressed in this section. I *think* these apply to 'jurisdiction-unit'. Can 
> you please make this clear?
> 
> I'm concerned that most of the specifications here are only RECOMMENDED. Who 
> makes the decision whether to follow these rules, and how can it be assured 
> that they are followed consistently? It is a problem if a consistent approach 
> to these isn't followed. For instance, when a reader of a document is trying 
> to create a LEX URN manually from a reference in the text, how will he know 
> whether to follow the recommendation or not?
> 
> (However, if the expectation is that an expert constructs the URN then this 
> is less of a concern.)
> 
> 4) MINOR: Annexes and Sub-Annexes:
> 
> When I read Section 6.4 the first time I was confused about the significance 
> of multiple annexes in a name - whether this refers to peer annexes of the 
> main document, or to a sub-annex of an annex. I later learned (in section 7) 
> that it means sub-annexes. This is an example of why the doc needs 
> reordering. Or else spell this out in this section.
> 
> 5) MINOR: "original" as document version
> 
> Both sections 6.6 and C1.2 discuss using "original" as the document version 
> to identify the original version of the document. But this is allowed to be 
> written in different languages. However it doesn't specify how the language 
> for this is chosen. How can someone constructing the URN from a textual 
> reference decide which spelling to use? More specification is needed.
> 
> 6) MINOR: Manifestation:
> 
> The following in section 6.7:
> 
>   Note that the value "all" can be expressed by language-dependent
>   equivalents. To indicate possible features or peculiarities, each
>   main element of the manifestation MAY be followed by further
>   specifications, for example as regards <format> the version, for
>   <editor> the archive name and the electronic publisher, etc.
> 
> doesn't appear to be normative regarding what the "specification" means for 
> any particular element. Rather it merely gives "examples". There needs to be 
> normative text defining the semantics. (Section 7 clarifies things to an 
> extent, but also isn't normative.)
> 
> Also, as with "original" above, the language to be used for "all" isn't 
> specified.
> 
> Also, by using semicolon to separate the format from its specification you 
> have excluded using semicolon to denote mime type parameters, as is 
> conventionally done. (E.g., in Content-Type header fields.) Some mime types 
> have mandatory parameters, so this will exclude using those types at all. 
> Some discussion of mime type parameters is needed.
> 
> The following example:
> 
>   - XML format (version 2.2 DTD NIR) of the text of the act and PDF
>     format (version 1.7) of the "Figura 1" (figure 1) contained in the
>     body, edited by the Italian Senate:
>     "urn:lex:it:stato:legge:2000-04-03;56$text-xml;dtd-nir-
>     2.2:senato.it:testo"
> 
> introduces further confusion, by mapping "XML format (version 2.2 DTD NIR)" 
> to "text-xml;dtd-nir-2.2". I see nothing that specifies how to perform this 
> mapping. Nor how to find out what this means. It appears to be very ad hoc. 
> Also, the XML Format is normally encoded within the XML itself, so why should 
> it be encoded in the LEX URN?
> 
> Then I had trouble deciphering the following example:
> 
>   the Spanish URN of the html format of the whole Judgement of the
>   European Court of Justice n. 33/08 of 11/06/2009, in Spanish version,
>   published in the Jurifast data base in anonymized form:
>   "urn:lex:eu:tribunal.justicia:sentencia:2009-06-11;33-
>   08@original:es$   the Spanish URN of the html format of the whole Judgement 
> of the
>   European Court of Justice n. 33/08 of 11/06/2009, in Spanish version,
>   published in the Jurifast data base in anonymized form:
>   "urn:lex:eu:tribunal.justicia:sentencia:2009-06-11;33-
>   08@original:es$text-html:juradmin.eu;jurifast:todo:anonimo"
> 
> As best I understand, "todo" is the 'component' and "anonimo" is the 
> 'feature. I discovered the Spanish "todo" means "everything" in English. So 
> apparently this means the anonymized form of everything. But how would 
> someone know to use "todo" or "everything"? Is the language for this word 
> determined by language tag in "original:es"? And even if the language is well 
> defined, how is the term to use ("everything" rather than "all", etc.) 
> determined? Again this seems underspecified, and may lead to interoperability 
> problems.
> 
> (Is this covered by section 7.2 that puts this responsibility on the 
> Jurisdictional Registry? If so, it would be good to have an exhaustive list 
> of things that the Jurisdictional Registry must define.)
> 
> 7) MINOR: Partition Identifiers:
> 
> It appears that section 6.8 is attempting to invent a one-off mechanism for 
> partition identifiers that is entirely redundant to the r- and q- components 
> of a URI as specified in RFC8141. ISTM it would be better to embrace those 
> mechanisms.
> 
> 8) MINOR: Resolution Examples:
> 
> While the high level intent of section 8.1 is reasonably clear, the details 
> are not. Some concrete examples showing relevant DNS records would be 
> extremely helpful.
> 
> 9) MINOR: Catalogs for Resolution:
> 
> While a catalog db for lex URN resolution (section 8.2) could offer some 
> advantages, it will be only as good as the content that populates it. For 
> such a catalog to be well populated it will probably need to be fed the 
> results of applying a good resolver algorithm, such as described in section 
> 8.3. If you have that, then the db really only serves as a optimizer.
> 
> I think this section needs better explanation.
> 
> 10) MINOR: Normalizing the Partition ID:
> 
> Section 8.3 says to separate the Partition ID and then use it determine what 
> to return. Not mentioned is that the partition ID itself may be inaccurate, 
> so normalization of it is also likely to be required. This may even involve a 
> trial and error mechanism to try different transformations of the partition 
> ID until the one that works is found. Again it would be helpful for the 
> document to mention this.
> 
> 11) MINOR: Returning multiple manifestations:
> 
> The following in Section 8.3:
> 
>   Lacking more specific indications, the resolver SHOULD select the
>   best (most recent) version of the requested source of law, and
>   provide all the manifestations with their related items.
>   A more specific indication in the uniform name to be resolved will,
>   of course, result in a more selective retrieval, based on any
>   suggested expression and/or manifestations components (e.g. date,
>   language, format, etc.).
> 
> implies that multiple items are to be returned. The form to return these 
> isn't specified. Are these to be returned as a single document containing all 
> this information? (May or may not be possible.) Or as multiple documents? 
> (Represented how?) For instance, if I'm looking for text/plain and there are 
> multiple annexes, will they come back as a multipart/mixed, or a zip of the 
> parts, or simply a concatenation of all the pieces as a single text/plain? 
> How will it know what I'm prepared to receive? (For some retrieval protocols 
> the types I can receive are specified in the request.)
> 
> 12) MINOR: Jurisdiction-code registration
> 
> Section 11.2 doesn't address what is to happen when a domain name that has 
> been used as a jurisdiction code is assigned to a different entity. (And can 
> this also happen for ccTLDs?) The old owner of the domain name may then get a 
> different domain name. And both the old and new entities may want to assign 
> LEX URNs. This situation needs to be addressed.
> 
> And regarding the IANA Jurisdiction-code Registry, it is common practice when 
> defining a new IANA registry to supply a template for what must be supplied. 
> Perhaps the first bullet list in section 11.2 is intended to be that, but it 
> is pretty vague, especially regarding the registrant. It should be more 
> explicit about what information is to be provided and the format for how it 
> is to be provided in a new registration and how it is to be represented in 
> the IANA registry.
> 
> 13) MINOR: jurisdiction-code syntax:
> 
> I suspect the following syntax in Attachment A:
> 
>   jurisdiction-code = 2*alf-dot
> 
> is not exactly what you want, though I'm not certain exactly what you do 
> want. I suspect you are trying to forbid a code that is a single character. 
> If so, then the following might be better:
> 
>   jurisdiction-code = alfanum alf-dot
> 
> 14) MINOR: ABNF ambiguities (Attachment A):
> 
> First, the rule 'specification' is used in a variety of contexts. But the 
> semantics differ with the context. I strongly recommend making them separate 
> rule names that correspond to the semantics they denote. And then refer to 
> the corresponding names in the text.
> 
> Also, the following is ambiguous:
> 
>   ;-------------------------------------------------------------------
>   ; Structure of the <authority> element
>   ;-------------------------------------------------------------------
>   authority = issuer *("+" issuer)
>   issuer = (institution *(";" body-function)) / office
>   institution = alf-dot
>   body-function = alf-dot
>   office = alf-dot
> 
> Something matchng 'alf-dot' could be either an 'institution' or a 'office'. 
> This can present problems when using tools to generate a parser from the ABNF.
> 
> 15) MINOR: Purpose of Attachment D (Http LEX Identifier):
> 
> There are no references to Attachment D within the body of the document, and 
> it seems entirely unnecessary to the understanding of the document. And it 
> doesn't appear to be normative.
> 
> Consideration should be given to moving this to another document describing a 
> system for using and resolving LEX URNs.
> 
> If it is to be retained in this document, then there should be a reference to 
> it from within the body of the document, explaining its reason for being 
> included.
> 
> 16) NIT: Use of "However":
> 
> Section 3.2 says:
> 
>   The "lex" NID syntax conforms to [RFC8141]. However, a series of
>   characters are reserved to identify elements or sub-elements, or for
>   future extensions of the identifier.
> 
> The use of "However" here is confusing. It seems to suggest that this is an 
> exception to conformance with RFC8141. If that is not what is intended, then 
> this should be reworded. For instance:
> 
>   The "lex" NID syntax conforms to [RFC8141]. A series of
>   characters are reserved to identify elements or sub-elements, or for
>   future extensions of the identifier. Hence only a subset of the
>   syntax allowed by RFC8141 is available for definition of local-names.
> 
> 17) NIT: Use of "Recently"
> 
> There are a couple of uses of "recently" that won't (haven't) age(d) well:
> 
> In the following text from section 2:
> 
>         The use of r- and q- components, recently introduced by
>         [RFC8141], with LEX URNs is not defined in this document.
> 
> RFC8141 is now almost three years old. I don't think you can still call this 
> recent.
> 
> There is a similar issue in the following from Section D1:
> 
>   Http URIs have been recently promoted as stable and location-
>   independent identifiers [RFC3986].
> 
> This same wording was in version -11 from three years ago, so it isn't very 
> recent. And if the "recent" reference is really in RFC3986 then it is much 
> older.
> 
> In both cases I think you should find more suitable wording that recognizes 
> that these are by now well established.
> 
> (THE END)
> 
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