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Response to Request for Information

Contents

Introduction ... 2

Practical note ... 2

Background ... 2

Answer to Question 1 & 2 ... 3

Question 1: ... 3

Question 2: ... 3

Answer to question 1 and 2: ... 3

Additional comments ... 4 Answer to Question 3: ... 4 Question 3: ... 4 Answer to question 3: ... 4 Additional comments ... 5 Answer to Question 4: ... 6 Question 4: ... 6 Answer to question 4: ... 6 Additional comments ... 7 Answer to Question 5 ... 7 Question 5 ... 7 Answer to question 5: ... 7 Answer to Question 6 ... 8 Question 6 ... 8 Answer to Question 6: ... 8 Answer to question 7 ... 9 Question 7 ... 9 Answer to question 7: ... 9 Additional comments ... 9 Answer to Question 8: ... 10 Question 8 ... 10 Answer to question 8: ... 10

Answer to Question 9 and 10: ... 10

Question 9: ... 10

Question 10: ... 10

Answer to question 9 and 10 ... 10

Additional comments ... 10

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Introduction

The Danish National IT and Telecom Agency (NITA) has on behalf for the Expert Committee on Open Standards (ECOS) established autumn 2008, send fourth a Request For Information (RFI) regarding the support of open document formats in Microsoft products. This document represents Microsoft response to this request for information.

Practical note

Microsoft has received the RFI from ECOS in Danish. Microsoft has for practical purposes asked for permission to reply in English. This permission was kindly granted by NITA on October 18th 2010.

Translation of the original text from Danish to English is written using italic in the remaining parts of this document.

The term ISO/IEC 29500:2008 (and later versions) is shorthand notation for referring to both ISO/IEC 29500:2008 and ISO/IEC 29500:2008 with amendment 1 and corrigendum 1. This reply does not speculate about versions, amendments or corrigendum’s etc. published later than the date for this reply unless clearly specified so.

Background

The basis for the request for information from the ECOS is specified the following way:

The basis for this RFI is those applications, which are being marketed by Microsoft, which are using the following listed open standards for document formats.

The standards that the ECOS expects to be included [in the reply] are those standards which will live up to criteria 1-3 as specified in the “Common understanding of the use of open standards for software in the public sector”, no later than January 1st 2011, which are the following standards, Corrigendum and amendment:

1. ISO/IEC 29500:2008:OOXML which includes:

a. ISO/IEC 29500-1:2008 Information technology - Document description and processing languages - Office Open XML File Formats - Part 1: Fundamentals and Markup Language b. ISO/IEC 29500-2:2008 Information technology - Document description and processing

languages - Office Open XML File Formats - Part 2: Open Packaging Conventions c. ISO/IEC 29500-3:2008 Information technology - Document description and processing

languages - Office Open XML File Formats - Part 3: Markup Compatibility and Extensibility – d. ISO/IEC 29500-4:2008 Information technology - Document description and processing

languages - Office Open XML File Formats - Part 4: Transitional Migration Features 2. ISO/IEC 29500:2008:OOXML w/ Amendment 1

3. ISO/IEC 26300:2006 Open Document Format for Office Applications v1.0

4. ISO/IEC 26300:2006 Open Document Format for Office Applications – w/ Amendment 1 (which creates technical alignment between OASIS/ODF 1.1 publiced in 2007 and ISO/IEC 26300:2006. Amendment 1 which is expected to be publiced i 2011).

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The ECOS has, as specified above, chosen to include not yet approved amendments, in the expectation that those amendments are to be approved by ISO and publicised no later than April 2011.

Answer to Question 1 & 2

Question 1:

Has Microsoft developed one of more Office Productivity Applications, which are capable of reading and/or writing documents in the formats as specified in one or more of the standards specified above (see

Background).

If, no please describe what specifically is preventing an implementation for the given open standard. If, yes please specify the applications name and version number, as well as answer the sub sequential questions for each if the applications.

Question 2:

Which versions of the standards (specify name and version number and amendment) does the application support?

Answer to question 1 and 2:

Yes, Microsoft have a number of Office Productivity Applications which are capable of reading and/or writing documents in the formats as specified in the RFI, specifically ISO/IEC 29500:2008, ISO/IEC 29500:2008 w/ Cor 1. & Amd. 1 and ISO/IEC 26300:2006 w/ Amd 1 (i.e OASIS ODF 1.1).

Application Version ISO/IEC 29500:2008 ISO/IEC 29500:2008 w/ Cor 1. & Amd. 1 ISO/IEC 26300:2006 ISO/IEC 26300:2006 w/ Amd 1 (i.e OASIS ODF 1.1) Microsoft mac: Office

2011 Read Read/write No Read/write

Microsoft Office

2010 Read Read/write No Read/Write

Microsoft Web Apps 2010

2010 Read Read/write No -

Word Pad Part of Windows 7

Read Read/write No

Microsoft mac:Office

2008, w/ SP2 Read Read/write No Read/Write

Microsoft Office

2007, w/ SP2 Read Read/write No Read/Write

Microsoft Office

2003 w/ SP 1 or later & compat pack

Read Read/write No (Read/Write)*

Microsoft mac:Office

2002 w/SP3 & compat

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4 pack Microsoft Office XP w/ compat pack

Read Read/write No (Read/Write)*

Microsoft Office

2000 w/ SP3 & compat pack

Read Read/write No (Read/Write)*

Microsoft Office Viewer

2003 w/ compat pack

Read Read No (Read)*

(X)* : requires the installation of a free of charge Open Source add-in that enables read and write of ISO/IEC 26300:2006 w/ Amd 1 (i.e. OASIS ODF 1.1)

There is no support for ISO/IEC 26300:2006 without amendment 1, as this standard is not widely used anymore. One of the reasons that ISO/IEC 26300:2006 is no longer used is that ISO/IEC 26300:2003 did not meet the functional requirements for providing basic support for accessibility for people with disabilities and/or special needs. Such basic functionality is provided in OASIS ODF 1.1.

Additional comments

Microsoft mac:office 2008 and 2011 as well as Microsoft Office Microsoft 2007 and 2010 has the capability to read both ISO/IEC 29500:2008 and ISO/IEC 29500:2008 w/ amendment 1, as well as the capability to write documents which are compliant with ISO/IEC 29500:2008 w/ amendment 1. All earlier versions of Microsoft Office listed above can read ISO/IEC 29500:2008 and write ISO/IEC 29500:2008 w/ amendment 1 and Corrigendum 1 with the free Microsoft Office Document Compatibility pack installed.

Obviously, earlier versions of Microsoft Office might have limitations in terms of what functionality they can present and edit, due to the simple fact that not all the newest functionality is present in earlier versions. However, the structure of ISO/IEC 29500:2008 and later versions is such, that no functionality is compromised in a round-trip scenario where the document is shared among different versions of Microsoft Office.

The reason that Microsoft Office 2007 and Microsoft mac:office 2008 and earlier are capable of reading ISO/IEC 29500:2008 with or without amendment 1, even though that those versions of Microsoft are earlier than ISO/IEC 29500:2008, is that ISO/IEC 29500:2008 is compatible with ECMA-376 1st Edition. Microsoft Office versions will write to ISO/IEC 29500:2008 with corrigendum 1 and amendment 1, as will all other versions in the list. This has to do with the fact that amendment 1 fixes some few (and from an

implementation stand point) minor issues, which nevertheless unwillingly broke the compatibility with ECMA-376 1st Edition. Cor 1 and Amd 1 fixes those issue.

Answer to Question 3:

Question 3:

Is the implementation in full compliance with the standard or is the implementation only partially so?

Answer to question 3:

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Additional comments

None of the standards in question here, specifies how an application should be implemented. All of the standards specify how document must be structured– i.e. how documents are persisted in a computer file that is stored by the application for later retrieval and/or sharing.

An application is understood to be in compliance with the document format standards, when the application is capable of reading and writing documents as specified in the document format standard. There is no requirement in either ISO/IEC 26300 or ISO/IEC 29500 for applications to implement every single feature of a document standard in order to be compliant. There exists no application that we know of in the market which has implemented every feature of any document format standard in question in the RFI.

All implementations listed above are capable of reading and/or writing (see details in the list) documents which are in compliance with ISO/IEC 29500:2008 w/ Amd. 1 and Cor. 1 according to the transitional conformance class.

All implementations listed above are capable of reading and/or writing documents (see details in the list) according to OASIS ODF 1.1, which according to the RFI is expected to be equal to the forthcoming ODF 26300:2006 w/ amendment 1.

As described above; for previous versions of an application – such as for example Microsoft Office 2000, which is more than 10 years old – some elements of the document might not be available for editing as a consequence of the continuing rapid innovation in the market place.

To ensure full transparency in regards to how Microsoft implements the open document formats in Microsoft Office, Microsoft fully discloses implementations notes at the following site and Microsoft encourages other vendors to do the same: www.documentinteropinitiative.org

Clarifying comments regard the use of conformance classes in ISO/IEC 29500:2008 (and later versions).

For an implementation to write documents that are in compliance with the transitional conformance class for ISO/IEC 29500:2008 (and later versions), means that such an implementation must write documents according all four parts of ISO/IEC 29500:2008 - i.e. part 1, part 2, part 3 and part 4.

Similarly, for an implementation to write documents that are in compliance with the strict conformance class for ISO/IEC 29500:2008 (and later versions), means that such an implementation must write documents according only three out of four parts of ISO/IEC 29500:2008 (and later versions) – i.e. part 1, part 2 and part 3. Documents that are compliant with the strict conformance class must specifically not utilize elements specified in part 4 of ISO/IEC 29500:2008 (and later versions). Consequently, such document will be limited and have limitations.

The Microsoft Office versions listed above are capable of reading documents adhering to the strict conformance class.

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The Microsoft Office versions listed above will all write documents according to the transitional conformance class, because utilizing part 4 of ISO/IEC 29500:2008 (and later versions) is considered necessary to meet current demands and expectations in the market place.

ISO/IEC has ratified the entire ISO/IEC 29500:2008 (and later versions) and thus utilizing either of the two conformance classes is in full compliance with the standard, as ratified by ISO/IEC.

Microsoft recognizes that there are interests in the market place that are working actively for a further refinement of the strict conformance class, and Microsoft actively supports this work as it takes place and evolves in the international standards community within ISO/IEC JTC1 SC34 now and in the future.

Answer to Question 4:

Question 4:

At which platforms (i.e. operating systems) can the application be run?

Answer to question 4:

Microsoft Office is available on multiple platforms.

Microsoft Office as a traditional and rich client application is developed to Windows and Mac. The latest release versions being Microsoft Office 2010 for Windows and Microsoft Office:mac 2011 for Mac. Microsoft Office as a web based application is available across all platforms supporting all recent versions of Internet Explorer, Apple Safari, Google Chrome and Firefox, which means that Microsoft Office 2010 Web Applications can be used by end users across Windows, Mac, Linux, Chrome OS, and most mobile operating systems such as Android, iOS and others.

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Application Version Windows Apple Mac Linux Microsoft mac: Office 2011 X Microsoft Office 2010 X Microsoft Web Apps 2010 2010 X X X

Word Pad Part of Windows 7 X Microsoft mac:Office 2008, w/ SP2 X Microsoft Office 2007, w/ SP2 X Microsoft Office 2003 w/ SP 1 or later & compat pack X Microsoft mac:Office 2002 w/SP3 & compat pack X Microsoft Office XP w/ compat pack X Microsoft Office 2000 w/ SP3 & compat pack X Microsoft Office Viewer 2003 w/ compat pack X Additional comments

Virtualization technology such as VMware, Citrix etc. is becoming more and pervasive, which means that desktop platform is becoming decoupled from which platform an application is created for.

Answer to Question 5

Question 5

If the application can be run in a browser, please state what server platform the implementation as well as the application can be run from.

Answer to question 5:

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The industry is in the process of making a big shift to the cloud. Services and applications offered in the cloud enables the users to access these services and applications across multiple platforms such as

Windows, Mac, Linux, iOS, Android Chrome OS and multiple devices from PC’s, notebooks, netbook, mobile phones, tablets etc.

Microsoft Office 2010 Web Apps is a web application, which can be run from any client platform supporting a Microsoft Internet Explorer, Google Chrome, Apple Safari or Firefox browser, which together covers close any PC mobile platform available today.

On the server side, Microsoft Office 2010 Web Apps is run on a Windows server platform. While this information is technically interesting it is irrelevant from a user and customer perspective, since users and customers and is able to access and utilize Microsoft Office 2010 Web Apps and similar web based

applications and services freely across multitude of platforms and devices.

Answer to Question 6

Question 6

Is the standard implemented for word processing, spread sheet and presentation? Please specify if there is a difference for the three document types.

Answer to Question 6:

Yes the standards are implemented for word processing, spread sheets and presentation. There is no difference in regards to standards implementation for the different types of applications.

In other words the standards are implemented for Microsoft Word, Excel and PowerPoint for each the Office versions as listed here:

Application Version Word processing Spread sheet Presentation Microsoft mac: Office 2011 X X X Microsoft Office 2010 X X X Microsoft Web Apps 2010 2010 X X X

Word Pad Part of Windows 7 X X X Microsoft mac:Office 2008, w/ SP2 X X X Microsoft Office 2007, w/ SP2 X X X Microsoft Office 2003 w/ SP 1 or later & compat pack X X X

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9 Microsoft mac:Office 2002 w/SP3 & compat pack X X X Microsoft Office XP w/ compat pack X X X Microsoft Office 2000 w/ SP3 & compat pack X X X Microsoft Office Viewer 2003 w/ compat pack X X X

Answer to question 7

Question 7

Does the implementation require that documents are being persisted in a format which, goes beyond the standard ratified and publicized by ISO?

Answer to question 7:

No, the implementations of Microsoft Office listed in this reply does not require that documents are being persisted in a format which, goes beyond the standard ratified and publicized by ISO

Additional comments

As pointed out by the Danish Competition Authority (see: The Market for Office Software1) the current versions of ODF has a number of ambiguities, underspecified parts and similar short-comings, which inevitably requires any implementer to make interpretations etc. about the implementation of the standard.

Obviously all vendors must make interpretations and choices when implementing a standard, specifically where a standard has ambiguity and/or is underspecified in certain areas. The implementation of OASIS ODF 1.1 in Microsoft Office is no exception. However, this does not mean that interoperability cannot be obtained. In fact, interoperability is for all practicalities reliant on more than just the standards, and for example requires that vendors are open for disclosing notes about their implementation of a standard as well as open to work with others.

Microsoft discloses all details about the implementation of the document formats in question in the RFI. All the detailed information can be found here, where the information is also maintained and kept up to date:

http://www.documentinteropinitiative.org/. Additionally Microsoft has a set of interoperability principals

for working together and fostering interoperability across the industry:

http://www.microsoft.com/interop/principles/default.mspx.

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Answer to Question 8:

Question 8

To the extent that the answer to question 3, 6 or 7 is negative please explain to what extent the application does not live up to a given standard?

Answer to question 8:

In question 3, 6 and 7 the answer provided states that the applications listed in this document does live up the standards in question.

Answer to Question 9 and 10:

Question 9:

To what extent are the applications on the lists provided are capable of converting from one word processing format to another format within the functionality ceiling without loss of information and formatting?

Question 10:

Are the applications capable of converting in a “round trip” within the functionality ceiling without the loss of information and formatting?

Answer to question 9 and 10

The applications are capable of converting from on word processing format to another word processing format to the extent that is such a conversion is possible with in the functionality ceiling without the loss of information and formatting. The same holds true for round tripping.

Additional comments

The two document formats have similarities but are also fundamentally different in a number of areas. A conversion back and fourth between the formats is possible but not fail proof. As a rule of thumb the simpler the document is the higher the chance there is that the conversion will be successful. The same holds true for round-tripping.

Fortunately for a comprehensive answer to these questions is that the work of evaluating the interoperability between ISO/IEC 29500 (and later versions) and ISO/IEC 26300 has already been

documented within the international standards community. The resulting work of this work can be found in this report written by the highly respected German university Fraunhoffer:

https://www.fokus.fraunhofer.de/en/elan/projekte/international/laufende_projekte/Dokumenteninterope rabilitaet/index.html

Additional note:

Generally conversion between document formats is not the only approach, nor necessary the most effective approach. In the realm of open standards there is nothing that prevents different vendors to implement support for multiple ISO/IEC standards. In fact, most office suites already support dozens of document formats already. This is not surprising, since multiple standards support within single

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applications in the realm of digital formats is more the rule that the exception, as seen in the area of digital sound, digital pictures, digital motion pictures, wi-fi, internet protocols (i.e. IPv4 and IPv6) etc.

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