[www-patentpolicy-comment] <none>

I write as a concerned owner of a (very small) business.

I am in particular concerned with section 3, item 3, covering 
Royalty-Free (RF) Licensing Requirements, which states:

"3. may be limited to implementations of the Recommendation, and to 
what is required by the Recommendation;"

My concern is that with the spread of small customized devices, this 
clause might limit the ability to use a particular standard in other 
environments.  I am currently developing some small programs for 
cell-phones, but there are many other devices that would seem like they 
might be shut out because they are not traditional web-browsing devices 
and use of the standard might not seem to constitute exactly "an 
implementation of the standard", especially if they are part of a chain 
of components that make use of some standard as an intermediate step to 
the final presentation of data to a user.

Ideally, I should like the see the clause removed as I don't think 
there is any way you can allow a kind of restriction that will not trip 
up a developer eventually and thus bring practical limits to the 
"standard" which otherwise would have none.

Thanks for your consideration,

---> Kendall Helmstetter Gelner