Subject: U.S. comments on OMG as PAS Submittor

From: "Lurvey, Barbara" <[email-masked]>
Date: Tue, 12 Aug 1997 12:36:26 -0400

Colleagues,
   Steve Carson asked that the U.S. share its comments on OMG's request
to become a PAS submittor with the other SC24 National Bodies.  The text
is below.

Jennifer T. Garner
JTC 1 TAG Administrator
[email-masked]

Dear Ms. Garner,

The following comments are submitted by Technical Committee H3 in
response to the request for comments on ISO/IEC JTC1 N 4801, the
application from OMG for recognition as a submittor of publicly
available specifications.  These comments are based on H3's experience
in working with OMG as counterpart to ISO/IEC JTC1 SC24.  I have also
attached reference document ISO/IEC JTC1/SC24 N 1284, which outlines the
difficulties encountered while working with the OMG, who was appointed
Class C Liaison status with ISO/IEC JTC1 SC24 during the initial phases
of the PREMO standard.

The following points summarize areas where we feel the ISO standards
development process exceeds that of most consortia based processes and
provides for the creation of viable, long lived standards which are
developed in the best interest for both the implementers and users of
the standards.

1.		The ISO standardization process is an open consensus
based process which provides for input by various types of experts
(through JTC1 ballots and public reviews).  ISO subcommittees are
required to coordinate standards development efforts with other
subcommittees as well as outside technical experts and other standards
developing organizations in order to ensure that the standards are of
the highest quality and usability.   
1.	
2.		The ISO process requires that a mature well founded body
of work with market relevance and national body participation be
established prior to originating a new ISO project.  However, when a new
project is established, the initial level of maturity of the founding
work may vary, due to the technical nature and complexity of the issues
to be resolved by the standard.  
3.		When an ISO JTC1 standard is published, the developing
ISO JTC1 subcommittee typically retains responsibility for maintaining,
revising,  and extending the standard as required utilizing the same
open consensus based process. 
4.		When work is submitted to ISO for publication, typically
ISO retains the copyright to the material. 

In the 1991, 1992 time frame, a research effort was started by a few of
the ISO/IEC JTC1 SC 24 participating national body members to ascertain
the feasibility of developing an object oriented multimedia standard.
The need was recognized based on current standards which addressed
presentation, interaction, and exchange of imaging and graphical data as
well as the growing need to further refine and incorporate mechanisms
which could address application requirements for enhanced interaction
and presentation mediums in an object oriented paradigm.

Throughout this feasibility study, Sun, IBM, and HP, all H3 committee
members at the time, led efforts to orient the H3 committee to the body
of work under development within the OMG.  Sun, IBM, and HP were at the
time and still are copyright holders of the material and believed that
the material would provide an excellent architecture/methodology upon
which to develop a multimedia object oriented standard.  Even though the
body of work was still in the early phases of development, the key
concepts and principles were fairly well established and provided a path
forward towards further refinement through the OMG.  OMG's membership
was increasing and the OMG was eagerly continuing to develop and mature
the material.  H3 was eventually convinced and proposed the usage of the
OMG material to SC24.  H3 provided experts to present the OMG material
to SC24 and eventually convinced SC24 to base the new PREMO standard
upon the OMG specifications.

ISO/IEC JTC1 SC24 established a Class C Liaison with the OMG and
continued development of the PREMO standard.  OMG participated to some
extent in the initial object model for PREMO and the development of the
PREMO foundation component.  At the time it was envisioned that the
standard would be developed in OMG's Interface Definition Language (IDL)
and would be well suited to be implemented on top of OMG's Common Object
Request Broker Architecture (CORBA).  In order to meet the needs of the
standard and with OMG's knowledge, SC24 worked to develop modifications
to IDL and submitted suggested revisions to the OMG.  It was determined
that OMG was not very willing to alter the IDL specification and that
SC24's liaison status had little or no bearing in SC24's ability to
participate in the OMG process.  In fact, even though SC24 held a Class
C Liaison with the OMG, SC24 did not receive OMG documents and was not
invited to attend or participate in OMG meetings.  In addition, SC24 was
requested to remove all OMG text from their standards, even though OMG
did not hold the copyright to the material, only a limited license.
Due to these problems, SC24 was finally forced to drop the usage of IDL
and the CORBA object paradigm from its work.  This decision did not
affect the overall usability of the standard, rather it delayed the
development effort and caused embarrassment to the US national body who
strongly urged cooperation OMG with and utilization of their
architecture.  It is important to note here that SC24 has not had these
types of problems with other Class C liaisons or organizations with
which they hold cooperative agreements (e.g. the Interactive Multimedia
Association, the VRML Consortium, the North Atlantic Treaty
Organization, and the Imagery Standards Management Committee)

H3 is also aware of the cooperation which has occurred between the OMG
and SC21/WG7.  The primary reason for the success of this liaison is due
to the fact that there is significant overlap between the two
organizations with respect to the work which is being standardized and
the typical liaison relationship which requires negotiation and
potential comprise by all parties involved is not truly a factor in this
case.  SC24, on the other hand, was not trying to standardize a present
body of OMG material, but was instead trying to utilize OMG's material
as a framework upon which to develop a new technology based standard.
This scenario did require two way communication and compromise in order
to ideally benefit both parties.  Based on this fact, we believe that
the scenario encountered by SC24 is more typical of what future
coordinating standards development efforts will most likely encounter
and what should be protected against by JTC1.   

H3 believes that a relationship with the OMG and standardization of its
material may be beneficial to ISO.  However, based on the text of the
current OMG submission, and our past experiences, it appears that what
is requested is for ISO to grant publication of OMG material without
having input to the development/finalization of the  standard or in the
resolution of defects and maintenance of the standard.  It is important
for JTC1 to make sure that the OMG will accept input from its
subcommittees in order to harmonize the transposed standards with the
current JTC1 body of work (both established and developmental).  If this
does not occur, certain conflicts will most likely arise which will be
hard to resolve due to the drastically varying standards development
approaches.  With the PREMO experience still fresh in our minds, H3
cautions JTC1 to coordinate the interaction of the JTC1 SCs and their
ability to participate in the transposition and maintenance of standards
with the OMG and recommends that OMG not be granted PAS submittor status
unless the following conditions are satisfied:

1.	The OMG process must be revised, with respect to PAS
submissions, such that JTC1 organizations holding Category C Liaisons
with the OMG can participate effectively in the OMG process.  At a
minimum, representatives must be able to attend OMG meetings, be granted
the right to speak at such meetings, and to submit items for inclusion
on the agenda.  Also, the OMG must accept contributions from JTC1
organizations and treat them in a manner similar to contributions from
OMG member companies.
2.	With regard to PAS submissions, OMG processes must be opened to
allow participation by all interested parties.  In particular and at a
minimum: (a) any organization or individual must be able to submit
technology to an OMG RTF; (b) public comment must be solicited,
accepted, seriously considered and properly resolved during all OMG
development projects; and (c) there must be provisions so that any
organization or individual who can make a contribution to the work of
the OMG and requests to participate can participate in its working
groups without being required to join the OMG.  This is due to the fact
that as it stands today, contributing experts would be required to pay
very high fees to gain the level of membership required within the OMG
to participate in the adoption and maintenance of OMG PAS submissions.  

	Sincerely,

William J., Protzman
	Chair NCITS H3
Attachment 1, ISO/IEC JTC1/SC24 N 1284

ISO/IEC JTC1/SC24 N 1284

Liaison Statement to the Object Management Group

SC24 has received the Liaison Statement from the Object Management Group
dated October 5, 1994.  In response, SC24 first notes that this
statement misrepresents  the history of SC24's involvement with OMG
specifications. The following chronology reflects SC24's view of the
history of this relationship.

History

1. In 1992, various OMG specifications were submitted to ISO/IEC
JTC1/SC24 by US NB at the request of Sun, HP, and IBM, who were (and
are) the copyright holders to the material. At the time these documents
were first submitted, the US NB established informal liaison with OMG to
insure they were aware of these submissions.

2. Both the OMG and Sun furnished SC24 with machine-readable forms of
various OMG specifications, including the OMA, CORBA and COSS
specifications, with the understanding that this material would be
incorporated into SC24's standards.

3. During 1992, 1993 and 1994, SC24 used OMG material in the PREMO
development effort, but found OMG specifications inadequate for our
purposes and derived enhanced material. The OMG was supplied with copies
of the PREMO ID, WD and CD text over this period (as well as copies of
all other SC24/WG6 PREMO RG documents.) All of these PREMO drafts
incorporated material based on OMG specifications.

4. Believing that a potential existed for a mutually beneficial
cooperative agreement for an open dialog, SC24 first requested that JTC1
grant the OMG Category C liaison status for the PREMO project in 1992.
This request was approved by JTC1 as soon as JTC1 authorized the
establishment of Category C liaisons in early 1994. SC24 appointed Drs.
Paul ten Hagen from the Netherlands (the Convenor of SC24/WG6) as its
liaison officer to OMG. (Although the SC24 Secretariat wrote a letter to
OMG informing them of this appointment, Drs. ten Hagen has not yet begun
receiving mailings from the OMG.)

5. The SC24/WG8 PREMO RG took an active role to ensure the success of
its liaison with OMG. The steps taken included:

	a) inviting OMG to attend ISO meetings;

	b) offering to send ISO representatives to OMG meetings; and

	c) placing the OMG on the mailing lists of the PREMO RG,
SC24/WG6 and SC24, as well as the e-mail reflectors for the PREMO RG and
for SC24.

6. SC24 was pleased that, in February, 1994, the OMG Director of Program
Management and Chairman of the OMG Liaison Committee, Dr. Jon Siegel,
attended a PREMO RG meeting held in Amsterdam. He assisted SC24 in
making modifications to material in the (then WD) version of PREMO.  At
this meeting, SC24 experts discussed problems with the OMG's CORBA IDL
specification and the upwards compatible changes that SC24 thought were
necessary to adapt the material to SC24's use. The OMG representative
did not object to these changes.

7. Mistakenly believing that OMG held the copyright to OMG
specifications, in May, 1994, an officer of the ANSI X3H3 committee,
acting at his committee's request, wrote to OMG, formally requesting
permission to incorporate OMG specifications in SC24's work. (SC24 has
since learned that the original submitters of the material retain the
joint copyright, from which they granted a license to OMG to publish the
specification.)

8. In June, 1994, SC24 held a plenary meeting where PREMO Parts 1 and 2
were advanced to CD status. Although invited to attend, OMG choose to
send no representatives. The PREMO RG wrote two liaison statements (SC24
N1195 and N1196) to the OMG listing the upwards compatible changes that
SC24 had made to CORBA IDL and requesting that OMG consider these
changes for incorporation in future versions of its specifications. No
response has ever been received to the technical issues raised in these
statements.

9. In July 1994, the US NB received a response to its request to use OMG
material in SC24 standards. In a complete turnaround from its previous,
cooperative attitude, the OMG rejected the request.

10. The US NB referred the rejection letter back to the original
submitters (Sun, HP and IBM.) Legal advice was sought from corporate
attorneys who advised that OMG was not, in fact, the copyright holder of
the material, but itself had only a limited license to use the material
granted by the original submitters, who included Sun, HP, and IBM. Based
on this, Sun agreed to grant the necessary permissions to adapt portions
of the CORBA and COSS specifications for use in SC24 standards.

11. Subsequently, SC24 received the attached strongly-worded liaison
statement to SC24 (SC24 N1279), threatening to cease further cooperation
with SC24 if it obtained permission to use OMG specifications from the
original copyright holders rather than OMG itself. Although the SC24
PREMO RG was holding a meeting in the US, to which the OMG was invited,
the week after the OMG issued this liaison statement, the OMG again
chose not to participate.

SC24's response

1. SC24 agrees with the OMG that:

	a) standards must be stable; 

	b) modification must be through an established, deliberate
process; and

	c) the appropriate way to modify an OMG specification is to
focus efforts through the OMG.

2. SC24 has considered a number of alternative ways to respond to OMG's
demands. While we do not agree that SC24 has used any copyrighted OMG
material without permission (since we had the permission of one or more
of the original copyright owners, including Sun, HP and IBM), we have
nonetheless reluctantly concluded that SC24 must take steps to ensure
that SC24 standards do not compromise OMG specifications.  We are taking
these steps because:

	a) The OMG appears unwilling to continue a cooperative agreement
with SC24 to contribute to the development of International Standards
with a cooperative attitude toward an open dialog. This is evident in
statements in OMG's October 5th liaison statement to SC24 (SC24 N 1279,
attached) such as: "This position is not going to change." This
demonstrates that OMG is unwilling to continue in an open, cooperative
dialog with SC24.

	b) The OMG is a closed organization that does not develop open,
consensus based specifications. There are severe restrictions regarding
who may submit a specification to OMG for adoption. Further, any changes
to such a specification cannot be made without the consent of the
submitter(s) of the technology. The OMG has shown that it is unwilling
to allow changes to be made to its specifications as they are adopted as
ISO standards through an open, consensus-based process, regardless of
the minimal nature of such changes.

	c) The OMG has attempted to control the adoption of its
specifications by retaining an inappropriate degree of intellectual
property rights. SC24 strongly feels that no Publicly Available
Specification (PAS)  should be accepted for transposition into an ISO
standard unless the owner of the specification agrees to place the
specification under the control of an ISO editor who will ensure that
appropriate changes are made to the document as it progresses through
the ISO process.

3. The object model in PREMO (CD 14478) has only a distant relationship
to any OMG source material.  Material from OMG's OMA specification and
many other sources were considered in the development of the PREMO
object model. The material from OMG sources, in particular, was found to
be unsuitable for direct use in an ISO standard due to various factors,
including its quality, the degree of consensus it represented, and its
alignment with existing JTC1 standards.

4. SC24 strongly believes that JTC1 should undertake the adoption of an
openly-developed, consensus-based set of standards for object
technology. These include an Interface Design Language, an Object
Request Broker, a set of Object Services and other infrastructure
required to support distributed object-based applications. SC24 has
considerable experience taking advantage of OMG specifications in our
standards and believe that -- while these OMG specifications are not
directly suitable for fast-track transposition into ISO standards --
they are an excellent basis for a normal ISO development process.

If and when openly-developed ISO object technology specifications become
available, SC24 will seek to harmonize its standards with them. Until
then, the integrity of SC24 standards must be protected by not
referencing non-open specifications.

5. The OMG claims that it has established a good working relationship
with SC21/WG7.  SC24 notes that this relationship is at an early stage,
roughly where the relationship between SC24 and OMG was over two years
ago.  At that time, SC24 also thought that it had an excellent
relationship with OMG. SC24 also notes that SC21/WG7's scope is the
abstract description of open interfaces. SC24 represent users of such
interfaces. For this reason, SC24 experts -- who have attempted to apply
OMG technology to real problems -- are more likely to uncover problems
than those who deal with the specifications at an abstract level.

6. SC24 will work hard over the next few months (through its liaison
officer to OMG and its other officers) to resolve the present
difficulties with OMG. If a mutually beneficial relationship cannot be
reestablished, SC24 must reluctantly consider requesting that JTC1
dissolve the Category C liaison status granted to OMG. SC24 is keen to
renew its formerly productive relationship with the OMG, and is working
to improve the relationship. If the OMG will drop its unreasonable
demands that its specifications must be adopted by ISO without change,
this reconciliation will be facilitated. Also, SC24 requests that OMG
give serious consideration to the requested enhancements to IDL to the
mutual benefit of all users of object technology.

Barb
[email-masked]