no to RAND licensing

   World Wide Web Consortium
   Patent Policy Working Group
   www-patentpolicy-comment@w3.org


     Dear W3C Patent Policy Working Group:

     I'm concerned about the recent Patent Policy Framework draft, which
     could allow W3C members to charge royalty fees for technologies
     included in web standards.

     In particular, I object to the inclusion of a "reasonable and
     nondiscriminatory" (RAND) licensing option in the proposed policy.
     I believe that the exclusive use of a "royalty-free" (RF) licensing
     model is in the best interests of the Internet community, and that
     RAND licensing would always necessarily exclude some would-be
     implementers, especially among open source and free software
     developers.

     I applaud the W3C for its tradition of providing open-source
     reference implementations and its work to promote a wide variety of
     interoperable implementations of its open standards. The W3C can
     best continue its work of "leading the Web to its full potential"
     by continuing this tradition, and saying no to RAND licensing.

     Sincerely,

     Deborah Lynn Whitlock
     xvdebbyvx@aol.com
     916.965.0230