Based on the exchange between Bob Scheuermann and Doug Anderson:

Bob: If I understand this correctly, I am in copyright violation if I  
manually create an implementation guideline for any transaction set  
without buying some table data from someone?

Doug: You are incorrect, unless you are selling that implementation  
guide.

Bob: I'm not selling, just creating for distribution to trading  
partners. So in that case there is no IP/copyright issue?

Doug: Yes, that is my understanding.

... and Mike's earlier comment:

"the intention of the policy was discussed as being targeted primarily  
at EDI software vendors and service providers who profit from DISA IPR"

... it would be OK to create generic implementation guides for all X12  
transactions, à la UN/EDIFACT, under an open source project and  
publish them as an "Open Source" product without being in violation of  
the IPR policy and having to pay license fees.

This would allow providers to include/use the data from the Open  
Source project in their applications/services and only charge for  
their added value (the rest of their product offering), a valid common  
practice by many commercial software vendors that include open source  
in compliance with the open source license.

Something worthwhile to look into should DISA/X12 go ahead with their  
new licensing program.

I find X12/DISA's action as rather backward thinking as other B2B  
organizations do exactly the opposite by publishing their EDI/XML  
structured documents freely on the internet for downloading without  
any license fees.

Klaus



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