My mail to the secretary on the subject. Please feel free to use any part and send it to the Secretary (IT) secretary at mit dot gov dot in

To Shri R Chandrashekar Secretary (IT), Department of Information Technology, Ministry for Communications and IT, Government of India

Dear Sir,

We refer to the above subject matter.

We are a small Company based in Mumbai, providing specialised goods and services to various public and private organisations in the IT software, hardware and embedded systems market. Typically our systems and services involve hardware, software, communications and embedded devices. These need to work with the IT systems of large organisations. As a result we are acutely aware of the need for standards and the concomitant politics that go into the formulation, implementation and maintanence of standards in the IT industry.

We have read the draft policy and appreciate the effort and thought that has gone into supporting the need for open standards.

However we also strongly object to 1) Changes being introduced by vested interests to support "multiple standards" 2) Acceptance of standards which are patent and royalty encumbered under RAND terms.

1) Multiple Standards

The arguments forwarded by these vested interests, typically representing very large IT organisations are as follows a) Multiple standards ensure competition b) Multiple standards exist elsewhere

Multiple standards do not increase competition. They merely form cesspools of entrapment. Users of one standard then have to bear hughe costs in order to interoperate with other standards. In many cases multiple standards came about because goods and services were already in wide spread use during the ongoing standardisation process and vested groups choose to deliberately ignore the process, thus carving a market for themselves. Various "technical superiority" arguments are also forwarded in support of such multiple standards. Thus we had the PAL /SECAM /NTSC standards, which came about because of both conditions ie wide spread use prior to standardisation (PAL / NTSC) and technical superiority SECAM. End users bore the cost of the additional circuitry in every tv required to interoperate. Broadcasters bore the cost of converting feeds from one standard to the other. Further multiple standards for most goods and many services did not exist in the same geographical location and thus they were in practice a single standard. However as a result of globalisation migration of goods and services led to forced adoption of multiple standards eg. Automobiles.

Thus adoption of multiple standards should be viewed as a failure of the standardisation process, instead of being touted as a justification.

Where ever introduction of enhancements to the existing standards is required, as a result of technology and requirements growing a few years downstream, the enhanced standard must compulsorily incorporate the legacy standard (data, protocols etc) as a subset, such that there is no degradation in performance and functionality. Also old applications must continue to work with a subset of new standard without any degradation.

Thus any example forwarded in support of multiple standards should be viewed with the utmost suspicion.

In the case of IT the "goods" in the form of data and services ride on a massive underlying national infrastructure. Existence of "multiple standards" anywhere in the chain drastically affects the entire chain.

2) Acceptance of standards which are patent and royalty encumbered under RAND terms.

The term RAND is highily subjective. Any standard which restricts it's use by setting of artificial barriers is self contradictory. Eg. GSM standard needs to be licenced from the GSM consortium with hughe payments (in excess of USD250000). Obtaining the specifications for CIFS (a network protocol for connecting windows PCs) requires a payment of USD10000.

The implementation of such encumbered standards - usually owned by a small not for profit consortium, whose members belong to large Multinationals - will be tantamount to the government mandating defacto use of the consortium member's goods and services.

We strongly object to the use of Patent and royalty encumbered standards, especially standards derived from patent encumbered software. I am sure you will be aware that parliament has specifically rejected software patents in India.

A recent example is the pathetic implementation of FYJC online admissions in Mumbai by the Maharashtra state government. (http://fyjc.org.in/) The first page is a defacto advertisement promoting the product of a single specific company.

India is very lucky in having a nearly clean slate in implementing e-governance projects. Please do not saddle ourselves with the mistakes and follies of other nations, being touted as examples of successful implementations of Multiple standards and royalty encumbered standards.