Date:               June 18, 2015
To:                  Steve Stevens, Executive Director, Accredited Standards 
Committee X9
From:              David Ezell and Erik Anderson, Co-chairs of the W3C Web 
Payments Interest Group (WPIG)
Subject:           Response to X9's Comments on WPIG's Use Cases and 
Capabilities Document
We appreciate the time and effort that X9 members to review the Web Payments 
Interest Group's (WPIG) Use Cases document.

We agree that this W3C effort is an ambitious one.  We also think it is a 
necessary and strategic effort given the increasing integration of the Web with 
worldwide commerce and the Web's access to billions of people.  The ambitious 
nature of this effort underscores the need for collaboration among standards 
development organizations such as W3C and ASC X9 - a collaboration that we hope 
to foster.

Several other points raised in your comments deserve clarification and feedback 
from us.

*         You suggest that our effort might be better expressed as "Web 
Commerce" versus "Web Payments."  This is consistent with other feedback we 
have been received on our use cases and capabilities work.  As you rightly 
observe, several aspects of what we are working on (e.g., trust, credentials, 
digital signatures, loyalty programs, etc.) extend beyond a payment transaction 
and are applicable to other standards efforts that may not even involve 
payments.  For example, credentials are needed to facilitate entitlements and 
digital signature constructs could easily extend to smart contracts and 
ownership of Web assets and information.  So, we will consider how we can 
better address the point that you and others have made.

*         Your feedback on roles, sequencing and information flows and 
suggestion that "Standardizing the vocabulary and the protocols for exchanging 
discrete segments of the payment mechanics would be of immense value" is 
helpful.  These concepts have been difficult to describe satisfactorily in the 
capabilities document. For example, depending on the "direction" of the payment 
interaction (e.g., payer initiated, payee initiated, account provider 
initiated, etc.), different sequences and flows result, generating a large 
number of combinations and permutations of complete commerce flows.  Thus, your 
suggestion to focus on discrete segments is intriguing.

*         Finally, your comment on the all-encompassing nature of the work has 
been raised in our own group's discussions. As a point of clarification, within 
W3C there are "interest groups" and "working groups."  The former tend to be 
broader in nature, generating a breadth of ideas that are the ultimately 
prioritized by the working groups that write the standards.  Nonetheless, one 
of the challenges we have been wrestling within the interest group is how to 
determine and focus on an initial set of features and capabilities to 
standardize, while at the same time encouraging participation of organizations 
in the WPIG who may want to drive other capabilities forward. We are already 
attempting to follow your suggestion of breaking the work down by discrete 
segments and capabilities to de-couple standardization work streams that must 
proceed at different rates and using different processes. We are approaching 
this challenge by defining more narrowly for the working groups the scope of a 
"version 1.0" standard and recognizing that some "requirements" will be 
addressed in later versions.
We look forward to continuing to work with the X9 community on this important 
effort.

On behalf of the Interest Group, we deeply appreciate your consideration.
Erik Anderson, Bloomberg (co-chair)
David Ezell, NACS (co-chair)
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