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Interoperability by Regulation: The Glass Half Full
Technorati Tags: Microsoft, US Department of Justice, interoperability, protocol specifications, documentation, protocol licensing, faux journalism, intellectual laziness
[update 2008-07-01T03:16Z Some additional updates were announced June 30. I account for those and the trade-press activity around them already. There is renaming to Open Specifications generally, not to be confused with the Open Specification Promise (although there is some overlap).
This is a very long post. I work through the history of Microsoft compliance with the consent decree and November 2002 final judgment in the civil anti-trust suit. I wanted to confirm how this is a continuous improvement activity with the provision of protocol specifications and licenses at center stage now that other major compliance actions have been carried out and are being monitored for continued satisfaction.
Because there is a perception, promulgated in what passes as the trade press, that Microsoft has not delivered and is perpetually promising delivery some day, I wanted to confirm the history and progress that has been made and that is easy to confirm using official documents and the online, public downloads of the Microsoft protocol documentation.
I also wanted to affirm how much this is a journey, it may not have a decisive end point, and the work to refine and correct and respond to difficulties in use of the documentation is an ever-expanding effort for good cause.
For simplicity, I do not track the parallel events that arose in conjunction with the European Commission judgment against Microsoft. This progression also maps to the availability of protocol documentation in compliance there also.
1. The Story So Far
1.1 The Development of Protocol Specifications and Licenses
The carrying out of the final judgment and consent decree in the civil anti-trust case between Microsoft and the U.S. Department of Justice (and other plaintiffs) is over-seen by a Federal Court judge. Part of the on-going review of the settlement involves a requirement that Microsoft document and license, under agreeable non-discriminatory terms, a variety of protocols used between separate Microsoft products. There is overlap with similar judgments that arose in Europe. The idea is to encourage competition by those who would employ the same protocols to also interoperate with Microsoft products and even offer competing interoperable products as substitutes and complements.
Until this year, if we were not someone involved in their development, licensed use, or review, we only knew anything of the process of delivering and improving the necessary specifications through progress reports and other communications from Microsoft, over-sight bodies, and other authorities. It's a bit like watching a football game during a heavy, pea-soup fog without being able to see the players and even know how the game is played. To top it off, the various announcers and commentators don't seem to be at the same game.
This year, the more-technical members of the general public are able to observe the delivery of such specifications in a direct way. As part of the February 2008 declaration of Interoperability Principles Microsoft provided the already-delivered documentation for on-line public access. This documentation was developed as part of the compliance effort. The initial materials consisted of 30,000 pages of documentation. In April, over 14,000 additional pages of drafts for additional protocols involving more-recent products were added. There are also on-line forums for discussion of the protocols, questions about details of the specification, and so on. [As a point of calibration, I am not an insider in this activity nor have I taken advantage of the available protocol documentation. I do have a personal curiosity about the FrontPage extensions and the patented Microsoft extensions to WebDAV.]
Licensing for all of these protocols and their formats where Microsoft has applicable patents is also provided under reasonable and non-discriminatory (RAND) terms, but you no longer need a license to access the specifications. Final specifications are promised as future updates in this ongoing Open
These are all in addition to the specifications that Microsoft has made available under the Open Specification Promise and which have been steadily growing since 2006.
1.2 The Technical Committee Assessments
Meanwhile, there is a three-person Technical Committee (TC), plus one expert assigned by the "California Group" of plaintiffs, that reviews the specifications as they are released and provides feedback to Microsoft and the Department of Justice. The TC has its own staff. The TC has broad access to Microsoft and its technical materials. The TC was appointed in 2003 and the TC term has been extended until November 12, 2009, the same date that already-extended portions of the final judgment will expire. (Some elements of the final judgment expired in 2007.) There is provision for further extension of the judgment and the work of the TC until as late as November 12, 2012. [My intuition is that such incremental extensions will occur.] Microsoft has declared that it will make no objection to such extensions.
The purpose of the TC includes assessing the technical availability, completeness and usability of the specifications for successful use by third parties. These reviews lead to requests for rewrites and other improvements in the materials and their coverage. The TC also develops tests that are usable in some degree of interoperability verification and are being made available to Microsoft for its use as well. Findings of the TC inform the court, Microsoft, and the Department of Justice (and other plaintiffs) of the progress and status of rewriting specifications and other activities to further the support for interoperability. Operation of the TC is part of the oversight process agreed among Microsoft, the Department of Justice, other plaintiffs, and incorporated in the final judgment.
On June 17, 2008, the latest Joint Status Report was filed with the court. This is the 17th such report (including interim reports as well as the twice-yearly ones required specifically by the court). The previous one was on February 29, 2008. The first one was on July 3, 2003. The complete list and texts of status reports and related documents are available on the U.S. Department of Justice web page for the case.
1.3 Useful Review
To understand the scope of all effort involved in carrying out terms of the consent decree and the final judgment, it is very useful to review the first Joint Status Report of July 3, 2003. There are far-reaching provisions that are implemented and constantly being reviewed. With regard to the provision of communication protocol documentation, the initial materials consisted of 5,000 pages, representing 90 man-months of technical writing effort, made available in August, 2002. At that point having the technical documentation was but a small part of the compliance activity being carried out.
It is clear from the outset that there is a valuable iterative process by which proposed compliance approaches, license structures, and resolution of received complaints are worked out. The progression of effort is quite revealing.
1.4 The Progressive Expansion of Technical Documentation
Although there were a number of protocol licensees by the time of the third report, January 16, 2004, there was also a complaint regarding "the sufficiency and completeness of the Technical Documentation that Microsoft provides."
By the April 14, 2004 interim status, the plaintiffs concluded that "the technical documentation needs substantial revision in order to ensure that it is usable by licensees across a broad range of implementations ... ." In its response, Microsoft recognized "that there is (and likely always will be) room for improvement given the scale and complexity of the undertaking. Microsoft anticipates that modifications and enhancements to the technical documentation will be an on-going process as Microsoft and the licensees gain more experience in working with the documentation, new versions of protocols are released, related technical information resources that Microsoft makes available are modified, and so forth."
According to the July 9, 2004 status, development of measures for completeness and a plan to revise the documentation by Fall, 2004 were underway. By the October 10, 2004 status, revised documents were being placed in beta release for review and concerns over the format of the documents were being addressed.
On January 25, 2005, it was reported that revised documentation had been made available in December, 2004. "Plaintiffs believed that the revised documentation represented a significant improvement over the original documentation. Plaintiffs nevertheless remained concerned that further work on the documentation was needed to provide confidence that licensees would be able to implement the relevant protocols." At this time, there was a significant expansion of technical developments to be used in verifying the protocol documentation:
According to the October 19, 2005 status, the TC projected that the prototype implementation would not be complete until July 2007. The extension was required by ramp-up delays, recognition of greater effort required, and finding more difficulties than expected with the available specifications. Microsoft offered these supplementary comments to what it agreed was a successful process:
The Microsoft protocol parser project was having serious difficulties and was being re-planned and redirected to provide useful results using alternative approaches, leading to a November 18, 2005 Microsoft Supplemental Report to the court. A January 23, 2006 Plaintiff Report added that there was a serious situation in the drop-off of responsiveness in handling of technical documentation issues. There were also difficulties around the setup and configuration of a test center in India.
By the February 8, 2006 interim status, Microsoft has offered to provide Windows server source-code access at no extra charge to licensees. This is proposed as a way to overcome the difficulties in maintaining the desired rate of responses to the technical documentation issues while the documentation effort is expanded. [Ed. note: I am amazed that this was considered. There are many reasons why reversion to the code as the authority is a bad idea, although it is difficult to argue with the desire to provide schedule relief. It is important to understand that the Court's measure of whether the specifications are successful and the remedies of the final judgment are effective has to do with the arrival of substantial competitive products that employ the protocols; the judicial clock is ticking.]
According to the May 12, 2006 status report, the availability of source code and a review of outstanding issues shows improvement, but not the high-level of resolution experienced previously. Microsoft proposes that resolving the technical documentation issues and making revisions one-by-one is ineffective. In considering a "reset" recommendation from Microsoft Senior Vice President Bob Muglia, the plaintiff's agree that a project to completely rewrite the documentation is preferable to the current revision approach under the conditions that "(1) the parties must agree on a specification for the new documentation; (2) the parties must agree on a project schedule for all the protocols; (3) Microsoft must rewrite the documentation for each protocol according to this schedule; and (4) the resulting new documentation must be tested and validated to ensure its completeness and accuracy. As it is clear that this project to rewrite the technical documentation will require a significant amount of time to complete, ... Plaintiffs have informed Microsoft that an extension of portions of the Final Judgments will be necessary, and Microsoft has consented to such an extension." The extended portions were originally scheduled to expire in November, 2007.
There is also rewriting required to satisfy the European Commission, so one could see how appealing a single, comprehensive rewrite could be. The US plaintiff's are impressed by the samples they are shown, but the current approach must continue until it is clear that the rewrite is producing what is needed. At this time, there is also new initiative to promote adoption of the protocols in third-party products:
According to the August 30, 2006 interim report, the plaintiffs and the European Commission are coordinating and Microsoft is estimating that the rewriting of the protocol documentation will occur in stages with completion in mid-2007. The plaintiffs are concerned with the estimate being so long. There is also to be addition of protocols and APIs that will be arriving with "Longhorn Server," the successor to Windows Server 2003. The TC and staff have grown to 40 people. The Microsoft team has grown to 245 Microsoft employees and contingent staff. The Microsoft Parser project has recovered and is making staged deliveries. The TC prototype work is now dependent on availability of the new, rewritten technical documentation.
According to the November 21, 2006 status, the first rewritten documents delivered in the first of five initial-availability milestones are recognized as improvements, although there is some disagreement on the template that was agreed to. This is worked out among the parties, along with an agreed review and correction process. Microsoft warns that the current schedule is aggressive and contains no buffer. The fifth milestone is targeted for May 29, 2007, with an online build of that milestone's reviewed/revised documents 90 days later. The Microsoft staffing has grown to 260.
According to the March 6, 2007 interim status, the first three initial-availability milestones were met on schedule. Microsoft has requested insertion of an additional "Longhorn milestone" before the original 4th and 5th milestones. This moves the final initial-availability to July 20 2007 with online build later. The Microsoft staffing has grown to 313. Microsoft notes that "the number of pages of documentation that Microsoft now expects to deliver as part of the rewrite project is significantly larger -- likely thousands of pages larger -- than Microsoft originally anticipated in Fall 2006."
On June 19, 2007 work is continuing. The TC decides it needs to hire some consultants for auditing Microsoft's identification of applicable protocols, following the discovery of some omitted ones. The plaintiffs repeat, at each status report since the rewrite started, that they will not be able to determine that the rewritten documents are acceptable until the full set is available. [Actual take-up in competing use appears to remain a shadow over the effort.]
According to the August 31, 2007 interim status, "the technical documentation project has proceeded according to schedule and Plaintiffs are encouraged by the quality of the new documents." The TC noticed that a number of protocol elements were removed from the new documents. The TC had expected that they would have been consulted before that was done. Microsoft agrees to locate all removals and review them with the TC. The online build of Milestone 5 is scheduled for September 28, 2007 [on schedule]. "Microsoft has committed to producing, at the same time, a final set of overview documents that explain how all of the protocols work together. As these documents are essential to ensure that licensees can make full use of the documentation to effectively implement all of the communications protocols, the TC will be reviewing them closely when they are produced." The Microsoft staffing has grown to 630.
By the February 29, 2008 status, additional protocols are being documented to cover an update to Windows Server 2008 (the "Longhorn" server) and other documents are to be updated by March 14, 2008. The protocol documents are now provided as part of Microsoft's Open Protocol Specifications under the Interoperability Principles.
At this point there is disagreement on the depth and content needed in the overview documents. The Plaintiffs and the TC assert that the quality of the overviews is critical and the scenarios need to be expanded along with other improvements. A template and revised contents are being negotiated with Microsoft. The Microsoft staffing has grown to 650.
2. The Current Situation
It is important to appreciate that major, extensive measures were required for compliance with the final judgment and the consent decree. In this broader context, the development of documentation and licensing of protocols were defined in but a few paragraphs of the final judgment.
Although I have mainly traced the progression of the protocol documentation effort, its growing significance is a consequence of all of the other actions having been successfully carried out, with their ongoing review and confirmation taking on a routine quality. There are still complaints that end up needing to be resolved and there are also many technical documentation issues being tracked. This should be understood in the same way as bugs are identified and tracked in software: there is no end to it, and some issues seem to persist far longer than others. Nevertheless, a systematic process for identifying issues, agreeing on resolution, and revising the documentation is in place.
According to the plaintiffs in the latest, June 17, 2008, Joint Status Report on Microsoft's Compliance with the Final Judgment, an interim report,
The plaintiffs identify three areas of current concern:
These seem to be natural occurrences as part of growing experience. The "regression" in regard to removal of protocol elements from the documents, and difficulty of identifying changes, is an important area for process improvement and better accountability. In the context of the overall progression from the 5,000 pages of documentation provided in 2002, I see this as a sign of maturation of an ongoing, iterative process for producing something that has no ideal measure of perfection. The practical measure is whether or not licensees and others are able to use the documentation successfully. This is also a matter for debate, with Microsoft agreeing to produce more while asserting that the available material is sufficient. This depends, I suppose, on the determination of licensees. The greatest practical concern appears to be the desire for determined licensees to appear on the scene and exploration of how that can be encouraged.
In this regard, the greatest outstanding technical-documentation activity is with regard to the additional overview documents which were first introduced in September, 2007. Following the concerns expressed in the February, 2008, status report, the plaintiffs report the planned resolution:
It needs to be understood that this is new, additional work, that the need for it was identified by Microsoft in 2007, and that the TC sees its quality as being critical. The TC also expects to see issues dealt with here that Microsoft had earlier declared would best be handled in what were then called overview (now "system") documents. In that context, the original rewrite is considered to be complete and now in what I would call continuation and maintenance status. It would not be unusual if the creation of the system documents led to some revision back into the protocol documents.
For its part, Microsoft reports that, as of June 1, there have been 146,000 downloads of the on-line, public documents. Microsoft staff for development of the documentation and testing of the protocols is now at 750.
Finally, Microsoft's tracking of Technical Documentation Issues (TDIs) is reported on a per-period basis in the status reports. In reviewing these numbers, it is important to notice that previously-closed TDIs are not accumulated. It would be very useful to review all of those reports and see how this works as a progressive activity. Although new TDIs are always coming in (including ones identified by Microsoft itself and by Microsoft in addressing queries from licensees), it is important to understand that this is very much like a bug tracking history. Showing only per-period activity tends to remove important perspective on how well this is working as a progression over time. I am curious to see if the increasing availability and visibility of the documents is also resulting in an increase in identification of TDIs. I'm not ready to fire up Excel just yet, though.
3. Public Perceptions and Debate
3.1 My Appraisal
When I first saw the popularly-cited June 21 commentary by Matt Assay, I had not reviewed anything but the current, June 17, interim status. That was enough for me to assert the following in a comment that same day:
I should add that attempting to develop comprehensive specifications without testing by outsiders is a guarantee of wasted work. The risk is over-explaining something that is obvious and/or irrelevant to others and overlooking those tacitly understood matters that outsiders will stub their toes on. Finally, it is not possible to write perfect specifications, although they can be evolved to be good enough. In this case, the "good enough" test is ensnarled with the Court's desire to see competition fostered, something that the documents can facilitate, but not cause.
Having gone deeper here, tracing through the entire history of this aspect of Microsoft compliance with the final judgment, it is clear to me how much this has been a learning experience, with several course corrections and expansions along the way.
I wouldn't be surprised to see wider availability of tests, examples, and even tutorials before this work is considered complete. The ability to build successful prototypes of the protocols using the specifications is a critical test. An even more important test will be the introduction of substantial third-party products that rely on the protocols and are able to fully demonstrate achievement of interoperability.
Everything we have before us is evidence of laborious progress toward that achievement. The glass is more than half full.
3.2 The Eternal Spotlessness of Lazy Minds
It is amazing to see the ways that the latest interim report is used as a launching pad for un-researched criticisms and complaints that have no foundation in reality. The progression of exaggeration and taking leave from the facts is quite impressive. I recount this particular drama to show how much even the simplest fact checking is apparently considered irrelevant to reporting on this effort and its status.
It is indeed fortunate that the source documents produced by the U.S. Department of Justice are online for all to see and verify. They are actually quite readable by non-lawyers, even the ones at Groklaw.
3.2.1 More-or-Less Balanced. There are relatively straightforward accounts of the June 17 interim status, with some degree of spin in the headlines, selection of emphasis, and presumed causality. Ars Technica led off with Jacqui Cheng's DoJ: Room for Improvement on Microsoft Antitrust Compliance, an advance over Jeremy Reimer's earlier US DOJ: Microsoft Dragging Feed on Documentation. InternetNews.com carried the Stuart J. Johnson report, DOJ Says Microsoft Cooperating but Slow, including an unsubstantiated (and already repudiated) claim of investigations in China. Some of these accounts seem to have the dates of various events (such as the final judgment) seriously muddled. There is also some confusion over the process of the European Commission versus those in the United States. [I have focused on the US-only aspects just for clarity of the timeline and the progressive expansion of the documentation activity.] The most balanced early account is the straightforward reporting in Dawn Kawamoto's CNet News.com blog entry, Microsoft, DOJ Issue Status Report on Interoperability Compliance.
3.2.2 The great Leap Out of Compliance. When the Groklaw reporting on the June 17 interim status is cited as more comprehensive than the status report itself, it is time to wonder about veracity. You'll notice that the Groklaw analysis, based on the same progression analyzed in section 1.4, here, completely overlooks that the 19 system documents reported in June are new work in addition to the 41,000 pages of technical documentation already delivered. The system documents replace a smaller selection of overview documents that were produced for the first time in September, 2007.
3.2.3 Here Comes the Judge. On Tuesday, June 24, the Federal Judge overseeing the Microsoft final judgment and consent decree held a meeting to review the June 17 interim status. Ina Fried provides a balanced report in her June 24 CNet News.com article, Judge presses for more from Microsoft. With all of the background here, it is straightforward to tie the reported remarks to the interim status and the history leading up to the system ("overview") documents that are under development. It is not clear, here, whether on-platform integration is also meant (requiring more documentation than that already covered by published APIs), or whether attention remains strictly on the communication protocols that work between services. This could be a confusion on the part of Judge Colleen Kollar-Kotelly or just in the coverage of the meeting. I expect it will be resolved over time as the system-document work proceeds.
3.2.4 The Empty Glass. Having not caught on to the fact that Microsoft's 19 system documents are new work that was found necessary beyond the current 41,000 pages of protocol technical documents, Matt Assay continues the great leap with his June 25 CNet News.com article, Microsoft promises to deliver interoperability documents by March 2009. The Assay perspective is that no documents have been released and Microsoft is withholding material that it must have available internally. The offered example seems to confuse API documentation (which is all fully available already) and the system documents that apply to the licensed communication protocols. It appears that Assay has not noticed that the June 2009 documents, with drafts all completed in March 2009, are the recently-defined additional ones.
Outstanding post. I had no knowledge about this, other than the very barebones facts.
This is an excellent summary indeed.
It's the same old, same old we saw in the Open XML bunfight.
It looks like Microsoft are making as much of an effort as anyone might be expected to do under the circumstances.
It must get to something when you essentially say "what do you want, blood? Have the source code, we're past caring"
I can see the next scoop from these ill-informed characters
"Nobel peace prize winner Mandela revealed as convicted terrorist - raised funds for paramilitary operations"
The National Enquirer beckons...
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