FWIW, here's the commented I submitted.
I just used email. The DOJ site discourages snail mail (worried about
anthrax, I suppose), and I figure if they are just counting "yea" and
"nay" votes, they can process email a lot faster than snail mail or
faxes.
- Jim Van Zandt
Date: 25 Jan 2002 21:10:51 -0500
From: "James R. Van Zandt" <[EMAIL PROTECTED]>
To: [EMAIL PROTECTED]
Bcc: [EMAIL PROTECTED]
Subject: Microsoft Settlement
Content-Type: text/plain; charset=US-ASCII
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I oppose the proposed Microsoft Settlement.
The proposed disclosure of APIs is not enough to allow free and open
competition in the development of applications and middleware. Here
are four significant defects:
The disclosure is too late. If API documentation is only released
at the "last major beta test" of a new product, then any competing
product would start with a handicap of several months, which in the
software industry amounts to most of a generation. There is also
no assurance that Microsoft would continue to use historical
patterns of beta testing. It could, for example, use a series of
test versions each released to only 140,000 beta testers. None of
these releases would then trigger the disclosure of the APIs.
Potentially significant exclusions. Excluded are "anti-piracy,
anti-virus, software licensing, digital rights management,
encryption or authentication systems". Without question, Microsoft
has legitimate needs in these areas. However, it is well known in
the computer security field that "security by obscurity" can work
only temporarily. True security is based instead on open protocols
and implementations that can be studied, criticized, and improved
by many developers. On the other hand, Microsoft can claim that
almost any API or protocol has some relevance to piracy, virus
protection, authentication, etc. If necessary some authentication
measures could be added to ensure this. This would give Microsoft
an excuse not to disclose those APIs.
Implementation roadblocks. If someone does implement a protocol or
API which Microsoft claims has anti-piracy etc. relevance, then
Microsoft can require them to pay a third party to test it.
Microsoft could easily use this requirement to delay and
financially burden the small companies and independent programmers
that have provided so many innovations in the software industry.
Excluded business areas. The agreement addresses only software for
"personal computers", apparently permitting Microsoft to set up new
monopolies in software for "servers, television set top boxes,
handheld computers, game consoles, telephones, pagers, and personal
digital assistants", which "are examples of products that are not
Personal Computers within the meaning of this definition".
For these reasons among others, I believe the proposed agreement would
not effectively prevent Microsoft from maintaining its monopoly in
personal computer operating system software, or from setting up new
monopolies in other business areas.
- James R. Van Zandt
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