The overwhelming majority view of the South African committee is that the scope of the overlap between the proposed standard and the existing ISO/IEC 26300 standard is significant. A significant majority view is that South Africa sees no benefit in adopting another standard for document formats in this area. Notwithstanding this view, and noting the limited time available to adequately study a specification of this length, the South African committee has detailed a number of technical defects in DIS 29500 which has informed its decision to not support its continued progress through the fast-track process. Given the extensive public interest that has been shown in this process, the South African committee has noted the extensive comments contributed by IBM and others that have become available in the public domain. We have studied these and concluded that, whilst we consider many of these to raise significant concerns, there is no extra value to be gained by repeating, via our comments to JTC 1, such concerns with which they will already be familiar. Whereas the comments submitted by South Africa are selected to highlight specific concerns, they are not exhaustive. Even for a highly technical document the proposed standard is extraordinarily convoluted, idiosyncratic and lengthy, making any attempt at compliance difficult. Failure to comply by a developer may however expose the developer to an intellectual property infringement claim.

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Proposed Disposition of DIS 29500 Comment ZA-0001 (Modified: 2008-01-08) We thank South Africa for its feedback and frankness, and we especially appreciate your decision to not submit known duplicates of comments submitted by other National Bodies. Regarding the overlap of DIS 29500 and IS 26300, we draw your attention to the following excerpt from `Response Document ­­ National Body Comments from 30-Day Review of the Fast Track Ballot for ISO/IEC DIS 29500 (ECMA-376) “Office Open XML File Formats”‘ 2.1.2 OpenXML Addresses Distinct User Requirements The OpenXML format standardization effort represent a very focused effort to write down in a standardized way the sum of information used in the already proven domain of existing binary formats while preparing for future enhancements and evolution. Although OpenXML and ODF are both intended to describe office documents, each is designed to satisfy different user requirements. OpenXML has been designed to be capable of faithfully representing the majority of existing office documents in form and functionality. It is designed to replace existing binary document formats with easily accessible, open formats to meet a wide variety of user needs, formats which capture identical information yet are extensively documented, and can be implemented on a wide variety of operating systems and devices. Meeting this objective, while also satisfying many other goals, imposes stringent requirements on the overall design and architecture of the format. Yes, our specification is long, but then it covers a very large area of functionality. (Note that while the specification for SpreadsheetML formulas alone required 325 pages, it is hard to imagine it taking any less.) However, an implementation need not conform to the entire specification as described in the response to JP-0027 with the definition of conformance classes. And despite some NBs’ concerns about the specification’s length, many other NBs’ comments have requested the addition of more text. 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). For detailed information about IPR in DIS 29500, please refer to the proposed disposition of comments AU-0002, BG-0002, CH-0004, CH-0019, GR-0001, GR-0015, IN-0006, IN-0070, IR-0057, KE-0074, KE-0075, NZ-0010, NZ-0054, PT-0001, PT-0003, PT-0004, US-0003 and ZA-0008.