Subject: Interoperability of TIFF FX

From: Scott Foshee <[email-masked]>
Date: Tue, 25 Sep 2001 16:28:51 -0700

Lloyd,

It is clearly stated that Adobe's 9/97 license grant was the purpose 
of Internet fax.

Dismissing the requirement to have TIFF FX pass Internet Fax 
interoperability requirements is clearly wrong.   You seem to defend 
progression of TIFF FX based on interoperability tests other than 
Internet Fax use, which is clearly outside the scope of the Adobe 
license.   It also raises a separate issue regarding the intended use 
of TIFF FX by those conducting non-Internet fax interoperability 
tests.

Thus, in addition to the TIFF FX specification being out of scope of 
Adobe's license grant, the IETF has yet to receive or consider 
interoperability tests that were conducted within the scope of the 
license grant.  Further, it would seem that the IETF process is being 
used to develop a standard with intended use and based on 
interoperability tests that are outside the stated scope of not only 
Adobe's license, but that of the working group.

It would seem that the IETF would want the 'intended use' of the 
standards it develops to be within the scope of 'stated purpose' of 
the working group performing the development.  Your interoperability 
comments indicate otherwise.

Given that the specification and the interoperability testing is out 
of scope of Adobe's license grant, it would seem that any 
implementation and use of TIFF FX is built on very shaky ground. 
This should be of concern to anyone building product based on TIFF FX.

I continue to support a plan that focuses on progression of just 
those parts that can pass interoperability testing as described in 
London.  Only in this case is it likely that license scope issues 
will be minimal or nonexistent.  Only then can product 
implementations be on firm ground.

Scott

At 4:47 PM -0700 9/11/01, McIntyre, Lloyd wrote:
>Larry,
>I am surprised that you of all people would be confused about what is
>appropriate for interoperability testing of a fileformat, such as TIFF-FX.
>Given your statement below, let me clarify for everyone's benefit that
>TIFF-FX is a fileformat and NOT an Internet Fax implementation, consequently
>http://www.ietf.org/IESG/Implementations/TIFF-FAX-implementation.txt
>satisfies the requirements, as confirmed by the IFax WG Chair.
>
>Lloyd
>>  -----Original Message-----
>>  From: Larry Masinter [mailto:[email-masked]]
>>  Sent: Monday, September 10, 2001 8:44 PM
>>  To: [email-masked]
>>  Subject: RE: Resolving TIFF dilemma
>>
>>
>>
>>  I was hoping we could make progress on the question of
>>  interoperability
>>  between existing Internet Fax implementations and typical
>>  configurations
>>  of email receivers and their image/tiff displayers. It would seem to
>>  be difficult to judge without actual data and sample files from
>>  actual Internet Fax implementations.
>>
>>  In any case, all of the implementations in
>>   
>>  http://www.ietf.org/IESG/Implementations/TIFF-FAX-implementation.txt
>>  are described as TIFF-(F)x reader/writer, not Internet Fax
>>  implementations.
>>  Shouldn't the criteria for Internet Fax interoperability be judged
>>  by implementations of Internet Fax?
>>
>>  Larry
>>
>>

---

From: Dave Crocker <[email-masked]>
Date: Tue, 25 Sep 2001 19:37:23 -0700

Since this rather frustrating topic is now being imposed on the mailing 
list, let us at least try to get the factual matters clear...

At 04:28 PM 9/25/2001, Scott Foshee wrote:
>It is clearly stated that Adobe's 9/97 license grant was the purpose of 
>Internet fax.

Scott,

Your interpretation of plain English differs from mine, markedly.  I do not 
claim to be an attorney, but plain English is pretty straightforward, and 
even attorneys are limited in their ability to change or invent meaning, 
after something has been written.

It appears that you are seeing a paragraph that gives some background, by 
citing the context of IETF motivation, and confusing it with the later, 
legal permissions contained in that note.

To be specific:

>Re: Referencing TIFF specifications from ISOC/IETF Standards
>
>Dear Mr. Heath,
>
>There has been a discussion of the use of the TIFF specification as the
>basis for the interchange of FAX data on the Internet.

So, the letter has now, correctly, cited the context in which discussions 
about TIFF have arisen.

>In conjunction with
>that work, Adobe Systems supports the use of and, hereby, grants you a
>license to use the  TIFF specification as the basis for an ISOC/IETF
>standard provided the following conditions are met:

The phrase "In conjunction with" does not state or imply limitations on 
use, other than the fact that "that work"  -- ie, the standardization 
effort -- be the context for TIFF standardization.  There is a long way 
between how something is standardized and how it is used.

To interpret this permission in the rather creative way you are suggesting, 
it would mean that no other IETF (or other) work could incorporate by 
reference the TIFF document that resulted from that work, and be 
legal.  Where is the language that imposes that constraint?

Attorneys are usually quite good at stating whatever restrictions they 
intend.  How is it that the restrictions you are claiming were not included 
explicitly and abundantly, in the usual style?

The paragraphs relevant to usage and conformance:

>3.      The name and text of the ISOC/IETF standard should make it clear
>that the ISOC/IETF standard is not a definition of TIFF but is, instead, a
>use of the particular TIFF  specification referenced. Adobe does not want
>to create confusion in the market with multiple, non-identical TIFF
>specifications.

This provides a rather specific point about usage, albeit concerning claims 
of authority.  It says nothing about fax, never mind restricting use to fax.

and:

>5.      Any file labeled as conforming to a particular version  of TIFF
>should be processable by a conforming processor of that version. (In the
>case of TIFF, processing of the Baseline TIFF requirements for the
>particular version is all that is required for conformance to TIFF.) If the
>files that conform to the ISOC/IETF standard are not processable by a
>conforming processor for the referenced version, then they should not be
>labeled with that version of TIFF or should be otherwise identified so that
>a conforming processor would not be confused.

The reference is to "a conforming processor" rather than "a conforming fax 
processor" or the like.

Again, no reference to fax at all.

d/

----------
Dave Crocker  <mailto:[email-masked]>
Brandenburg InternetWorking  <http://www.brandenburg.com>
tel +1.408.246.8253;  fax +1.408.273.6464