All Interface Technologies by Market Dominators should be QA-ed, RAND-z Standards!

by Rick Jelliffe

The trouble with standards is that there are not enough of them. There is a strong public interest in having the interface technologies of market dominators (which would include near monopolists and long-term super-profit-takers) out in the open, unencumbered, zero royalty, non-discriminatory licensed, and with the documentation QAed by an independent group which may include experts and rivals and stakeholders.

And there is indeed a great system set up for this: ISO, the International Organization for Standardization.

First, I should clear up a misunderstanding that many people fall into: a technical standard (from ISO) is not a regulation. According to ISO, It is always the adopter's responsibility to look at the available specifications and see which ones are useful, and in which contexts.

Second, for ISO standards, multiple standards for the same area the norm not the exception. In fact: look at the dozens of standards for graphics formats, the multiple standards for programming languages, the multiple standards for operating systems, the multiple standards for schema languages and so on. Putting a proprietary standard through the standards mill does not prevent other rival technologies becoming standards, nor does it necessarily obsolete an existing standards. Standards are not a race.

Next, I would like to mention that ISO has a very wide range of publication types, from International Standard to Technical Report to Publicly Available Specification, and it certainly may be the case that some technologies (such as obsolescent or fast-changing technologies) would be better made available using a lesser type.

My key point is that once a company's success in an area brings it to the point of market domination (or long-term super-profit-taker) then anti-trust regulators need to ensure that their interface technologies are open enough for the usual level-playing field concerns to be addressed. It needs to be just a cost of doing business, once you reach a certain point.

Obviously this applies very directly to Microsoft. But IBM is also a market dominator (indeed, monopolist) in the mainframe game. And Google looks similar for search; Apple with the iPod; Adobe with PDF; and so on. There may be non-American companies that it applies to as well, I suppose. (And there are technologies that achieve market dominance outside a dominant vendor: PKWARE's ZIP for example. These need to be standardized as well.)

The current standardization effort for DIS 29500 (Office Open XML) provides a good backdrop for this. For almost two decades, independent software developers have been calling on Microsoft to open up their interface and document formats: the SAMBA developers for example. In 2004, the European Union recommended to Microsoft that it should put its document formats forward (in an XML version) for international standardization. As Microsoft has done this, first through ECMA then at ISO, it is prompted a vicious campaign against the effort, lead by business rival IBM but also by stakeholders allied to some open source software substitutes for Microsoft Office. (In particular, stakeholders allied to the Sun lead Open Office application and the ODF format; note however that other Open Source stakeholders, notably those allied to Novel have welcomed the standardization effort.)

Some of the objections to DIS 29500 are in fact objections to the idea of a Microsoft-derived technology becoming a standard. In fact, several standards have come that way. The recent ISO Open Font standard, for example, it based on MicroSoft and Apple's Open Type fonts (True Type, etc).

Other objections to DIS 29500 come from the other direction: DIS 29500 is flawed not because of what is in it, but because of what is outside its scope: media formats, macro languages, printer driver configurations, and so on. The most extreme version of this argument is to find a fault with DIS 29500 that it does not describe the (50 or so different) earlier binary formats for Office and its component products. (When this complaint is made in the same breath as saying that the 6000 page draft is too large, it does smack a little of insincerity.)

I usually respond by pointing out that a standard needs to be scoped, that standard is a work-in-progress, that it is impossible for ISO committees and National Bodies to have enough volunteers to do this work (both because experts are scarce and valuable, and because idealism is not stimulated by contact with market dominators.)

But I should have been articulating this: yes, there should be documentation for the binary formats, and indeed any format, API or protocol used for interfacing computer systems which gain market dominance. There does need to be more rather than less, and the cost (which are ultimately costs of decent QA and education, once the spurious controversy that has unsuccessfully attempted to derail DIS29500's progress is over. (Of course, the lack of a tangentially related standard is no reason to reject a standard, we need to start from somewhere.)

Now many businesses are naturally coming to opening up their technologies in a similar way: look at Sun, for example, with its Open Solaris, Open SPARC, and its steps towards opening up Java. Public policy makers need to foster a procurement and regulatory environment where the winds of change for openness also blow refereshingly on market dominators.

The European Union was completely correct in asking for MS to adopt standard notations (XML) for the Office documents, and to standardize the schemas (through DIS29500), just as they were right to ask OASIS to standardize ODF (IS 26300). However, I hope this is the start of a larger movement for more: all document formats, all APIs, all protocols which have significant market domination need to be made available through one of the ISO standardization processes. All these interfaces are objects of legitimate interest for public policy for reasons of information ownership, level-playing field access, anti-trust, and even just from a procurement angle to ensure that systems are adequately documented and have had adequate attention paid to internationalization, harmonization, accessibility, and conformance testing: basic QA. And where the market dominating technology belongs to a market dominated by a single player (or cartel), then that player needs to bear the cost of the standardization effort, as a normal cost of business.

Now, my proposal here is not a total package: issues of conformance with external standards still need to be in place. After the statement "Here's what we do" comes the natural question "Is it good enough?", and that belongs in a separate blog.


2007-12-05 06:36:22
Thanks... that's the clearest explanation I've heard yet for why the existence of OOXML is a good thing. And it clearly applies with even hand across the industry.
Kurt Cagle
2007-12-14 13:26:22
Good argument and summary.

The one point I'd raise in objection (and its a philosophical one) is that there is an implicit endorsement in a standards body approving a technical specification from a single private company, especially if there are not strong safeguards in place that will ensure that adoption of a given proprietary standard does not in fact open up the adoptee to potential litigation for the development of applications around that standard.

Should I build an application suite that utilizes OOXML, I need to have guarantees that I will not be sued, or that I will not be liable to pay royalties on each particular instance of such a suite. Without such guarantees, ISO standardization is meaningless, and simply shows that the organization is available for sale to the highest bidder (the same arguments go for all single sponsor submissions, of course) and provides yet another marketing bullet for the sponsoring organization.

Indeed, this is a big part of the reason for the W3C requirement that a given working draft must have two distinct working implementations prior to approval as a recommendation. Perhaps there should be, as you hint around, a separate classification for "public disclosure" standards, such as PDF or OOXML, something for which there is a palpable need (I will not disagree with you about the need for a Microsoft Office XML standard) but which does not necessarily require granting a royalty free patent license or multiple implementations (and which as a consequence provides a lesser endorsement by the standards body).

Rick Jelliffe
2007-12-15 05:57:02
Kurt: Have you ever checked out any of the legal or patent details for any other standard you have ever used? What about PDF? What about ODF? What about ZIP? If your philosophical objection is towards one company only (and a company that does not seem particularly keen on lawsuits) then it is a prejudice, with respect. For example, have you checked out OSP versus IBM or Sun's similar licenses?

Actually, yesterday I attended a conference put on by UNSW lawyers to discuss OSP. I will blog on it separately.

2008-02-05 06:57:52
What is ZRAND? It is not explained in your article...
Rick Jelliffe
2008-02-05 22:06:40
Andre: I'll change it to RAND-z since that seems more common.
2008-03-26 18:47:23
Thank you for this great information, there was many people (me too) who have many misunderstanding about this.