Dear John, all the public comments must have an official answer and we are in the process to delivery them. We have an internal procedure for answering to the Public comments according with the OASIS rules, as all international standardization body has. We are managing the answers in proper order following the discussion in the LegalDocML TC. In meantime please find in your email account the email answer of KUSTER Marc, July 22nd. We strongly believe in a cooperative and constructive dialogue, in the reciprocal respect of the mutual institutional roles, for arriving to a good solution without loose the interoperability. Best regards, Monica Palmirani Il 26/07/2016 14:04, John Dann ha scritto: D'est Monica, There have been no feed-back twice on our comments on the Public comments. You replied to others comments received later, have you received and seen the comments below. As you are aware the equal footing for the naming conventions is at most importance. Thanks for your feedback, John Sent from my iPhone On 22 juil. 2016, at 12:32, KUSTER Marc (OP) <
Marc.KUSTER@publications.europa.eu > wrote: Dear Monica, Fabio, Thanks for taking up the idea of the functionally equivalent naming convention. However, currently the ELI naming convention seems to be only partially accommodated but subject to AKN conditions as opposed to being on “ an equal footing” and this will need to evolve significantly. Please find here the ELI TF's and OP's reactions. I am, of course, at your disposal for further discussions. Best regards Marc From: monica.palmirani [ mailto:
monica.palmirani@unibo.it ] Sent: 20 July 2016 11:44 To: John Dann; John Sheridan Cc: Fabio Vitali; Catherine Tabone; 'Søren Broberg Nielsen (957sbn)'; Patrice Platel; 'Matthews, Gerry'; Jean-Michel THIVEL; 'Nina Koch (957nko)'; 'Hietanen Aki (OM) (
aki.hietanen@om.fi )'; SCIARRINO Valeria (OP); KOENIG Kurt (OP); MALAGON Carmen (OP); SCHMITZ Peter (OP); PAPPALARDO Roberto (OP); KARDAMI Maria (OP); BAGOLA Holger (OP) Subject: Re: [legaldocml] Public Comments Dear John & John, we were wondering if you have received any comment about our proposal for the modification to the compliance with the Akoma Ntoso naming convention. Tomorrow we will have our LegalDocML TC meeting and it would be nice to have some inputs on this issue. We intend to speed up the standardization process soon, especially since Monica was elected in the OASIS Board of Directors. All the best, Monica and Fabio Il 12/07/2016 13:57, John Dann ha scritto: Hi Monica, Thanks for taking into consideration our comments. I forward your proposition to the ELI TF, as I sent the comments on behalf of all, and also the OPUE, whose comments we all supported, so they can also react. I am sure we will find a suitable flexible solution. John From: monica.palmirani [ mailto:
monica.palmirani@unibo.it ] Sent: Tuesday, July 12, 2016 12:04 PM To: John Dann <
John.Dann@scl.etat.lu> ; 'Sheridan, John' <
jsheridan@nationalarchives.gsi.gov.uk> Cc: Fabio Vitali <
fabio@CS.UniBO.IT> Subject: [legaldocml] Public Comments Dear John & John, during the last LegalDocML TC, on June 29th, the group has analyzed your comments and discussed about a possible way to satisfy both your concerns and our need to preserve the consistency of our overall design of the Akoma Ntoso proposal. In this message we would like to advance to you, informally, the gist of the solution, and once we receive your approval, proceed to actually draft and emit a new version of the documentation for the formal approval procedure. Briefly, the most relevant and pivotal comment is on the naming convention and on your request to allow on an equal footing other naming conventions than Akoma Ntoso's own one. We understand the request and the underlying need, and we are inclined to accept that as long as we can express a few simple and reasonable requirements. In brief, we would like to adopt your concept of functionally equivalent naming convention (FENC), specify that only FENCs are acceptable in Akoma Ntoso XML documents, and provide a few reasonable indications of what we mean by functional equivalence. A functionally equivalent naming convention is defined as follows: [ELI + OP] Disagree with most of these requirements. Why are they needed? Some of these requirements are highly subjective (when is something memorizable , global etc.)? Who would measure these and decide on the possible compliance as functionally equivalent naming convention? Any naming convention that declares itself to be functionally equivalent, is persistent and well publicly documented must qualify. 1) * recognizable * : a syntactical means exists to recognize the specific syntax used for the URI (e.g., a specific prefix); [ELI + OP] This would largely be the case for ELI (and ECLI), but why this requirement? Also the /eli/ part is _not_ a mandatory part of the ELI identifier syntax (and the UK doesn't have it…). 2) * published * : a sufficiently detailed description of the syntax is publicly available and backed by a recognizable institution; [ELI + OP] OK (assuming that recognizeable institution = relevant stakeholder). Otherwise, badly defined 3) * FRBR compliant * : A full distinction between distinct intellectual creations , specific intellectual forms , physical embodiments and exemplars of relevant documents must be explicitly supported and aligned with the FRBR conceptualizations. Support for items is not necessary nor requested. [ELI + OP] Why is this relevant at the identifier level? As it is formulated, it is unclear if ELI complies to this or not 4) * CEN Metalex compliant * : the seven rules in CEN Metalex requirements (section 6.1 of [1]) must be fully implemented: To allow for the discovery of IRI identifiers, names must be: 1. Persistent: names at all levels must maintain the same form over time regardless of the political, archival and technical events happened since their first generation; [ELI + OP] OK 2. Global: all relevant documents by all relevant bodies must be represented; [ELI + OP] What does this mean? Documents are globally accessible or the scheme is globally applicable? If the last, why? What are all relevant bodies ? 3. Memorizable: names should be easy to write down, easy to remember, easy to correct if they were written down wrongly; [ELI + OP] In principle OK, though subjective 4. Meaningful: names should mean something; It should be possible to make assumption about the kind, freshness and relevance of a citation by looking only at the document’s name; [ELI + OP] OK (but what does freshness mean) 5. Guessable across levels: references to different levels of the same document must be similar; e.g., given a reference to an _expression_ a user should be able to deduce the name of the work; [ELI + OP] OK 6. Guessable across document classes: references to different instances of the same document type must be similar; and [ELI + OP] OK 7. Guessable across document components: references to different components of the same document at the same level must be similar. [ELI + OP] OK 4) * active * : at least one working, accessible, available, robust resolver must exist that provides dereferencing of URIs/IRIs according to the specific syntax; [ELI + OP] No resolver must be required, unless this includes is the general http resolution mechanism 5) * equivalent * : at least one working, accessible, available, robust converter must exist that converts URIs/IRIs according to the specific syntax into equivalent URIs/IRIs according to the Akoma Ntoso Naming convention; [ELI + OP] In this case the Akoma Ntoso Naming convention is the privileged partner and not a choice on an equal footing . In practical terms, who would maintain such a converter? 6) * evident * : Akoma Ntoso XML documents identifying themselves (in <FRBRUri> and <FRBRThis> elements) using a FENC URI, must also provide equivalent <FRBRalias> elements with the URI ref corresponding to <FRBRThis> according to the Akoma Ntoso Naming Convention, one for each of the first three FRBR levels. [ELI + OP] Unacceptable. As an effect of this everybody would have to support the Akoma Ntoso naming convention in any case, the only difference being that in this case ELI is the primary schema and Akoma Ntoso the obligatory second one. In this, the Akoma Ntoso naming convention retains a privileged position and is not at all on an equal footing Any Naming Convention that complies with these requirements is termed a * functionally-equivalent Naming Convention * and its URIs can be used in any situation where Akoma Ntoso URIs/IRIs are appropriate. Finally we resist at allowing custom syntaxes for inner-document ids in eId and wId, because a) inner document identifiers are a reflection of the overall XML structure, which is still Akoma Ntoso, and not of the document-level URI syntax adopted, b) allowing multiple syntaxes for the same attributes would create havocs in any decent resolver and editor trying to deal with documents coming from different sources, and c) a good destination for custom ids already exists, attribute guid, that has exactly the stated purpose and allows custom ids without polluting the id space expressed by eIds and wIds. [ELI + OP] Using the prescribed syntax must not be requirement for compliance to Akoma Ntoso nor for the use of the eId / wId attributes. If desired, an additional compliance level could be defined for those users of Akoma Ntoso who want to use a resolver. The use of a resolver must not be forced on users of the schema who have no interest in using this functionality. So, usage of a predefined inner identifier structure should be an option (CAN), not an obligation (MUST), except perhaps in said specific compliance level [1] ftp://ftp.cen.eu/CEN/Sectors/List/ICT/CWAs/CWA15710-2010-Metalex2.pdf We plan to work on a new draft including this kind of flexibility, and would appreciate your opinion within the next week. Thank you for your comments and opinions on this. Monica and Fabio Il 21/06/2016 08:48, John Dann ha scritto: Dear members of the LegalDocumentML As Chair of the ELI Task Force, and on behalf of · Denmark · Finland · Ireland · Luxembourg · Publications Office of the European Union (comments also sent individually) · United-Kingdom (comments also sent individually) · France we would like to send the following comments. Constructing a universal naming convention, given the differences in national legal systems, is very complex and does not cover all national legislation cases and especially hinder existing naming conventions. In line with the principle of proportionality and the principle of decentralization, each country and company should continue to operate its own national Official Journals, Legal Gazettes or legal databases in the way they prefer. We should therefore carefully consider not to impose a naming convention in order to respect the legal and constitutional differences between countries, and authorize on equal footing other naming conventions, e.g. URN-Lex, ECLI, ELI etc. This flexibility would help the implementation of the revised version of AKN. We therefore fully support the comments of the Office of Publications of the EU sent earlier by email. Best regards, John John Dann Directeur LE GOUVERNEMENT DU GRAND-DUCHÉ DE LUXEMBOURG Ministère d'État Service central de législation 43, bd Roosevelt . L-2450 Luxembourg Tél. (+352) 247-82961 . Fax (+352) 46 74 58 E-mail :
john.dann@scl.etat.lu www.legilux.public.lu -- =================================== Associate professor of Legal Informatics School of Law Alma Mater Studiorum Università di Bologna C.I.R.S.F.I.D.
http://www.cirsfid.unibo.it/ Palazzo Dal Monte Gaudenzi - Via Galliera, 3 I - 40121 BOLOGNA (ITALY) Tel +39 051 277217 Fax +39 051 260782 E-mail
monica.palmirani@unibo.it ==================================== -- =================================== Associate professor of Legal Informatics School of Law Alma Mater Studiorum Università di Bologna C.I.R.S.F.I.D.
http://www.cirsfid.unibo.it/ Palazzo Dal Monte Gaudenzi - Via Galliera, 3 I - 40121 BOLOGNA (ITALY) Tel +39 051 277217 Fax +39 051 260782 E-mail
monica.palmirani@unibo.it ==================================== -- =================================== Associate professor of Legal Informatics School of Law Alma Mater Studiorum Università di Bologna C.I.R.S.F.I.D.
http://www.cirsfid.unibo.it/ Palazzo Dal Monte Gaudenzi - Via Galliera, 3 I - 40121 BOLOGNA (ITALY) Tel +39 051 277217 Fax +39 051 260782 E-mail
monica.palmirani@unibo.it ====================================