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Public Comment on ETRM Draft 4.0

Information Technology Division
Commonwealth of Massachusetts
Attention: Beth Ann Pepoli

Re:      Public Comment on ETRM Draft 4.0

Dear Ms. Pepoli:

In the interest of full disclosure, I am the Manager of Technology
Services for OASIS.  However, the comments below are rendered solely
in my individual capacity as a resident of Massachusetts and as a
proponent of open standards, and have not been requested, reviewed or
approved by OASIS, the Open Office community, or by any other parties.

In 1992 I was an investment broker for (then) Dean Witter in
Wellesley, MA.  It was the leading branch outside of Boston.  Aside
from managing millions of dollars in investments for my clients, I was
also the volunteer branch technology coordinator - helping Dean Witter
brokers leverage technology to enable their businesses.  For example,
I created a monthly newsletter to educate and build relationships with
my clients and the investment public.  The software that I used to
create my newsletter was Microsoft Publisher v1.0.  I was proudly
doing 'desktop publishing' including a nice layout and design

Time went by, and and about 3 years later I bought a brand new
computer.  I purchased some software to go with the computer, and was
excited to get the newest version 2 of Microsoft Publisher.  I was
curious to see how many improvements had been made in the area of
desktop publishing.  To my complete dismay, the new version of
Microsoft Publisher would not open the files produced by the earlier
version of Microsoft Publisher.  In fact there was /no available
software/ to read these files.  The only software to read these files
was the original program - which by now was not installed on any
operating computer that I owned - nor was it available for purchase.
Being stored in a binary file format, I could not even use tools to
extract the plain text portion of the newsletters.  My documents, and
the history they embodied have been locked away ever since.

That was how I learned how file formats - especially binary ones -
could completely own the data that you thought was yours.  I still
have those newsletters on floppy disk. I would gladly send them,
paying all the costs including return postage, to anyone who can
transcode them to an open, implemented, standard file format like ODF.
 If you put them into OOXML then I will not have any software that can
read them.

If Microsoft has a terrible track record of providing compatibility
for it's own customers with it's own products, then what possible
confidence can we have that OOXML will be an open standard offering
compatibility with other vendor products and other file formats?

I am extremely proud of the initiative and brilliant policy set by the
ITD in recognizing the benefit of open standards in file formats.  The
ITRM set out in 2005 put Massachusetts on the map globally in both
technology and government.  The ODF file format is the foundation for
good information stewardship and providing low-cost, open, effective

I see none of those same merits, benefits or characteristics in OOXML.
 It is telling that Microsoft uses the name 'Office Open' and the word
'XML' in order to confuse the marketplace and disguise their
intentions.   I am certain that if the ITD places OOXML on the same
level as ODF it will be a costly mistake. Massachusetts and all her
taxpayers will surely suffer consequences.

Let's keep moving forward with the true and open standard of ODF.
This way the Commonwealth will indeed be a wealth of the commons.

Gregory Rundlett
Newburyport, MA

Manager, Technology Services
Billerica, MA

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