CCIA Letter to Ecma International

Letter from CCIA President, Ed Black, compares OpenDocument to the Internet protocol, TCP/IP. Is it so?

CCIA to Ecma: 'Reject MS Office XML proposal.' It is not open. Endorsing single-vendor technology is not what standards bodies are established to do. Innovation & competition occur on open standards these days. Insist on true openness.

Dec. 7, 2005

Mr. Harald Theis
President
Ecma International

Dear Mr. Theis:

Tomorrow you will hold a preliminary vote on the proposed establishment of an Ecma International standard around Microsoft’s Office XML formats. On behalf of the Computer & Communications Industry Association, I respectfully request that you reject this proposal.

The Computer & Communications Industry Association has supported “Open Markets, Open Systems, Open Standards” since our inception in 1972. Members employ more than 600,000 workers and generate annual revenues in excess of $200 billion.
We support openness because it leads to greater competition, lower costs and more innovation. Open standards, moreover, prevent vendors from designing technology control points that keep customers locked in long after they want to switch to other products.

No one begrudges any company the opportunity to make new versions of its products compatible with previous ones. The larger problem is the frustration that arises when businesses, consumers and governments must deal with “standards” that are simple ratifications of what almost any proprietary software company would do in the normal course of business.

Microsoft, in fact, has promised the world an open standard. On Nov. 21, Microsoft’s Jean Paoli said: “We are expanding the language of the current royalty-free license to specifically enable developers who work only with open source licensing to also be able to work with Office Open XML. This will enable any customer or technology provider to use the file formats in its own systems without financial consideration to Microsoft.”

There can be doubt of the importance of this proposal. Hundreds of millions of people are dependent on Office software for their daily computing needs. Yet, for all of its importance, the proposal before you does not meet basic principles of openness. It provides no assurances as to third-party access or implementation of the standard. The proposal does not call for open management and control. In fact, it indicates that no one can introduce or remove features from Office 12 save Microsoft itself. Lastly, there is no assurance that the Microsoft will actually support the standard should it disagree with actions taken by Ecma.

The Commonwealth of Massachusetts, which rejected Microsoft’s earlier XML proposal -- indeed the world -- demands far more. Innovation requires that there be strong and productive competition in the marketplace. In the ITC sector, this means that standards must include the participation of many technology developers in order to assure the widest degree of adoption and interoperability.

Because open standards are by definition controlled by no single party, they facilitate interoperation among suppliers, partners, peers, and customers. Standards such as HTML, XML and TCP/IP maximize choice, minimize production costs and make competition work for customers of all kinds. In the long run, market forces work better, and vital records can be preserved forever -- not just for two or three product cycles. This proposed standard assures none of these things.

Mr. Theis, the world is at a crossroads. Much, if not most technological progress today takes place in a milieu of open standards. Rather than approve this proposal as is, we urge you to insist on true openness. You should demand more of any vendor that brings a standard to your committee. If Microsoft’s proposal is to have any meaning at all, competitive vendors and open source developers must have a strong role in its development. Microsoft, likewise, should promise to develop within the confines of the standard it puts forward, and should license any intellectual property within Office 12 so that all developers can be assured that their software licenses will not conflict with Microsoft’s. Once again we urge you to reject the proposal.

If I can be of further assistance, please do not hesitate to contact me.

Sincerely yours,

[signature]

Ed Black
President & CEO