From Barbara.Lurvey@eastmansoftware.com Tue Aug 12 18:30:54 1997 Received: from tuna.wang.com ([150.124.136.4]) by dkuug.dk (8.6.12/8.6.12) with ESMTP id SAA28989 for ; Tue, 12 Aug 1997 18:30:51 +0200 Received: from res02wnt246.corp.wang.com (res02wnt246.corp.wang.com [150.124.24.168]) by tuna.wang.com (8.6.12/8.6.12tf1) with ESMTP id MAA14486 for ; Tue, 12 Aug 1997 12:30:45 -0400 Received: by res02wnt246.corp.wang.com with Internet Mail Service (5.0.1458.49) id ; Tue, 12 Aug 1997 12:36:28 -0400 Message-ID: From: "Lurvey, Barbara" To: "'SC24@dkuug.dk'" Cc: "'bjl'" Subject: U.S. comments on OMG as PAS Submittor Date: Tue, 12 Aug 1997 12:36:26 -0400 X-Priority: 3 MIME-Version: 1.0 X-Mailer: Internet Mail Service (5.0.1458.49) Content-Type: text/plain; charset="iso-8859-1" Content-Transfer-Encoding: quoted-printable 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 jgarner@itic.nw.dc.us 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. =20 1.=09 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. =20 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.=20 4. When work is submitted to ISO for publication, typically ISO retains the copyright to the material.=20 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. =20 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;=20 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 Barbara.Lurvey@EastmanSoftware.com