It is not acceptable for an international standard to be designed primarily around the goal of compatibility with a particular company’s products. Justified by JTC1 Directives section 1.2 Interoperability, Annex I Interoperability Policy. Established: DIS 2950 is related to MS file formats. Established: It is common JTC1 practice to issue stan-dards of imperfect interoperability, such as JPEG1, JPEG2000. Established: Major Swiss users accept OOXML for its improved interoperability. Rejected: Based on the preceding claims established, it was rejected that it should not be acceptable of OOXML to be primarily targeting MS file formats. The comment is not admissible by JTC1 Directives sec-tion 13.4, as clearly being a contradiction to be ad-dressed during the review period, no longer applicable during the 5-month ballot. This is particularly inappropriate where, as in the pre-sent case, compatibility with an existing international standard is neglected in favor of the one-sided goal of maximal compatibility with document file formats intro-duced by one company, and where the proposed stan-dard does not provide equal opportunities for compatibil-ity to that company’s present and future competitors. Rejcted, as not justified by JTC1 Directives and practice. Unless this shortcoming of DIS 29500 is fixed, accepting this specification as a national or international standard would be a violation of Swiss and international law. DIS29500, which is related to Microsoft file formats, does not explain the mapping to ODF.

Change the goal from being "fully compatible" with "existing investments in Microsoft Office documents" to seeking at attain the same high level of compatibility not only with Microsoft’s formats, but also with the international norm ISO/IEC 26300 (OpenDocument). Review the entire draft standard and modify it corresponding to this revised goal. Add to introduction: "Attention is drawn to DIN document (MS to provide reference) regarding mapping between OXML and ISO 26300 - 2006."

Part 1, intro-duction (page xii) and entire document

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Proposed Disposition of DIS 29500 Comment CH-0002 (Modified: 2008-01-11) We thank Switzerland for its participation in the DIS 29500 Standardization process. In response to the issue around the goal of faithfully representing the pre-existing corpus of word-processing documents, presentations, and spreadsheets that are encoded in binary formats defined by Microsoft Corporation As noted in the Ecma whitepaper “Office Open XML Overview” at http://www.ecma- international.org/news/TC45_current_work/OpenXML%20White%20Paper.pdf ), under “Purposes for the Standard”: OpenXML was designed from the start to be capable of faithfully representing the pre-existing corpus of word-processing documents, presentations, and spreadsheets that are encoded in binary formats defined by Microsoft Corporation. The standardization process consisted of mirroring in XML the capabilities required to represent the existing corpus, extending them, providing detailed documentation, and enabling interoperability. At the time of writing, more than 400 million users generate documents in the binary formats, with estimates exceeding 40 billion documents and billions more being created each year. The original binary formats for these files were created in an era when space was precious and parsing time severely impacted user experience. They were based on direct serialization of in-memory data structures used by Microsoft® Office® applications. Modern hardware, network, and standards infrastructure (especially XML) permit a new design that favors implementation by multiple vendors on multiple platforms and allows for evolution. The scope of DIS 29500 is consistent with these goals. We also note that many organizations have requested that such a standard be created. For example, at its meeting of 25 May 2004, the European Union specifically recommended that “Microsoft should consider the merits of submitting XML formats to an international standards body of their choice.” ( http://ec.europa.eu/idabc/en/document/2592/5588 ) In response to the request to merge with the ODF standard There are currently several XML-based document formats in use, each designed to address a different set of goals or requirements. These include ISO/IEC IS 26300 (ODF), China’s UOF, and ECMA-376 (DIS 29500 ­ Open XML). All these formats have numerous implementations in multiple tools and multiple platforms (Linux, Windows, Mac OS, hand-held devices). In all cases there are features that exist in one of the formats but not the others. It may be a goal for future groups to work on harmonization of two or more of these formats, but that is not within the scope for the first version of DIS 29500. The Ecma Response Document from the Fast Track 30-Day contradiction phase for DIS29500 addressed the question of harmonization by explaining the differences between the ODF and Open XML formats as follows: “… one must recognize that creating a single “merged” format to address the user requirements of both ODF and OpenXML is a much more difficult goal–one that is hindered by fundamental obstacles comparable to what one might encounter while merging HTML and ODF or HTML and PDF. This is because of sheer difference of scope, feature and architecture. Ecma believes that one format cannot simultaneously meet the requirements that would come from the merge of the two formats and the stringent requirements of backward compatibility that drive the design of OpenXML. First, while both formats share the high-level goal, to represent documents, presentations, and spreadsheets in XML, their low-level goals differ fundamentally. OpenXML is designed to represent the existing corpus of documents faithfully, even if that means preserving idiosyncrasies that one might not choose given the luxury of starting from a clean slate. In the ODF design, compatibility with and preservation of existing Office documents were not goals. Each set of goals is valuable; sacrificing either at the expense of the other may not be in the best interest of users. Second, the resulting differences are not merely variances in scope that could be resolved by adding capabilities to one or the other. They are structural and architectural in nature. Where functionality overlaps, the corresponding elements nonetheless differ in precise meaning, usage, capabilities, options, and interaction with other elements. Even more importantly, the corresponding elements do not exist in isolation, but are components of whole document models, with different rules and constraints for such things as page/slide layout, flow, style inheritance, event processing, relative positioning, calculation order, formula dependencies, chart construction, graphic templates, animations, and so on. The resulting variations are not merely cosmetic. They compound to create qualitative disparities that, although perfectly acceptable for much of the user base, can be significant for organizations that require high fidelity in layout, content, or editability. Differences between the implicit page style model of ODF and the explicit page style model of OpenXML, differences in the models for splitting table cells, differences in the style information associated with spreadsheet cells, and differences in the full formula specification used in spreadsheets are only small examples of the hundreds of explicit design decisions that ensure the information included in the existing formats is represented faithfully in the OpenXML format.” There are many translation tools already in existence that enable interoperability between different formats by providing useful translation capabilities between ODF, Open XML and UOF. As has been noted in the suggested changes the German national standards body, DIN, has a committee, NIA-01-34 (see http://www.fokus.fraunhofer.de/fokus/fokus/presse/meldungen_fokus/2007/05/DIN- E.pdf ), that is preparing a Technical Report on the translation of documents between the IS 26300 and DIS 29500 formats. The members of NIA-01-34 include format experts from a number of countries, working together to define the numerous differences between these formats. Ecma strongly supports any harmonization effort that enables better sharing of information and allows better translation between the formats in the following way: Ecma believes that the work of the DIN (NIA-01-34) committee is essential to any harmonization effort. The work of DIN (NIA-01-34) will enable the industry at large to understand the detailed differences between the formats. Based on this detailed understanding, the ODF and Open XML formats could be extended in the future in order to enable better sharing of information and allow future translations tools to provide even better translation and interoperability between the formats. Harmonization would require functional changes to two International Standards and would fall under the JTC 1 procedures for new work within SC 34 and could be done in the future. Such work should not be done in this Fast-Track process and should not impede the adoption of DIS 29500. We note that a growing number of implementations of ECMA-376 are becoming available, including those released by Apple (Mac OS X Leopard, iWork 08, iPhone), Adobe (InDesign), Microsoft (Office 2007, Office 2003, Office XP, Office 2000, Office 2008 Mac OS X), Novell (Suse Open Office) , Google (Search / Preview), Mindjet (MindManager), Intergen, OpenXML/ODF Translator (Open Source project on Sourceforge), Dataviz (DocumentsToGo on Palm OS, MacLinkPlus on Mac OS X Leopard), NeoOffice, Altova (XMLSpy), MarkLogic (XML Content Server), Datawatch (Monarch Pro), QuickOffice (QuickOffice Premier 5.0 on Symbian), Altsoft (XML2PDF Server 2007) and those under development by Corel (WordPerfect), AbiWord, Gnome (GNumeric), Xandros, Linspire, Turbolinux and others. These implementations are now available on many platforms, including Linux, the Macintosh, Windows, and handheld devices (PalmOS, Symbian, Windows Mobile).