Objection to the RAND licensing option in the proposed policy.

BlankDear W3C Patent Policy Working Group:


     We are a small home based business which derives family income from
     the current environment of the WEB.  However, because your RAND licensing             option within the draft, large business could usually pay any licensing fees, the         small business could not.  This in affect will "kill" our business, and therefore our         family income.

     In particular, I object to the inclusion of a "reasonable and
     non-discriminatory" (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.

   RAND licensing may still shut out open source/free software,
   non-commercial, and smaller commercial software developers. While
   large companies can easily pay (and routinely do pay) license fees in
   order to implement technology, small developers and those who
   distribute software at no charge may find even the most "reasonable"
   licensing terms to be a significant barrier.


     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.

    The "Royalty-Free" (RF) licensing tradition is
   worth defending, and best serves W3C's mission of developing the "full
   potential" of the web as an open medium.


     Sincerely,

        Fred Sturman, C.O.O.
        Binary Data Systems
        1932 Aspen Drive
        Lewisville, Tx. 75077

email: fsturman@BinaryDataSystems.com