Peru - INDECOPI

 

There certainly is a need for an open XML standard. We consider that the proposal is very valuable and interesting. However, the size of the document makes an appropriate evaluation in the short time available very difficult. A number of errors, incompatibilities, voids and access and intellectual property restrictions that could be verified point to the need of a more detailed revision of the document in order to be a good international standard. The technical committee encourage ECMA members to present their proposal through the normal ISO standard development process, in order to enable an open discussion, an appropriate revision of all requirements and an adequate correction of all issues.

 

 

Paragraph 2

Page 2522 Lines 14 to 19.

 

The date representation does not allow dates before 1900.

Exists incompatibility between the format to handle dates and the Gregorian calendar.

 

A new format must be used for date representation that allows dates before 1900 and handles the Gregorian calendar.

 

Page 2523 Line 1

 

Year 1900 is wrongly considered as leap year in the OpenXML specification , although it is not because even if it is a multiple of 4 it is not multiple of 400.

 

A new format must be used for date representation that does not treat the year 1900 as a leap year.

 

Page 1650 (Earth Art Border)

 

There are icons in the specification where the world map is shown but Asia cannot be seen.

 

The world map needs to include Asia to be compliant with the cultural adaptability principle.

 

Page 750 Lines 5 to 9.

Page 68 Lines 29 to 32.

 

Not all is XML inside the proposed OpenXML. Exists proprietary content ("binary") inside OpenXML that can be subject to intellectual proprietary claims of Microsoft. This applies also to the use of bitmaps in the specification, for example in the Supported Unicode subranges.

Other example is the use of binaries in the Custom Property Part as a binary space, where closed binary extensions could be used.

 

Format m ust be fixed to ensure that all content is in XML without proprietary aspects. Also exist XML text in the specification with errors that must be fixed.

 

Page 4955. Enumeration Value list

 

OpenXML includes references to Windows functions that can be protected by intell ectual propriety of Microsoft, for example reference to EMF and WMF (windows formats), but does not include references to PNG (Open standard format) used in Linux.

 

Remove any reference to windows functions and include references to open standard formats, to allow interoperability.

 

 

The number o validation of schema errors indicates that the specification has not been through a rigorous technical review

(http://surguy.net/articles/ooxml-validation-and-technical-review.xml).

 

Fix the errors listed in the referenced web page

 

 

The access to the proprietary references is restricted.

 

Include references that do not have proprietary restrictions

 

 

The proposal is too large to review in 5-months. 6,000 pages is not appropriate for a Fast Track proposal

 

Remove OpenXML from Fast Track process and refer it to an SC34 Working Group for further technical review and consensus building

 

 

Effort should be dedicated to improve ODF instead of propose an alternate standard

 

Develop OOXML starting from ODF.