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U.S. Copyright Office and the LGTM Standard

Part Two of a thread about the U.S. Copyright Office’s request for input asking if “persons filing the electronic-only [copyright] preregistration form prescribed by the Copyright Office will experience difficulties if it is necessary to use Microsoft’s Internet Explorer web browser in order to preregister a work.” (Also see coverage by

I’m hoping that by the end of this post you are willing to take just ten minutes to take a stand on behalf of standards, equitable access to information, and good government.

I ran into the LGTM Standard when working with a (now-former) vendor that had promised valid, accessible website code but from my eyeball standards, I could see, fell very short of the mark. I had the code externally tested (since they were not conducting testing internally; so help me, at one point the vendor said they would charge extra for valid code!), and when I presented the results to the vendor, the response was, in essence, Looks Good To Me. In other words, if it looked o.k. in Internet Explorer, well, gee, it met the standard, didn’t it?

This experience is just one reason I’m asking you to find some paper and an envelope and write the Copyright Office to present the case for ensuring their site can work in multiple browsers (or, to be more accurate, user agents, since some blind or otherwise challenged users use special software or hardware that falls outside the area of browsers as we know them). There’s just something not quite right about a government agency asking for permission to test with one user agent in order to develop a form for what seems like such a minor task.

To address just one arrow poking out of the quiver of those issues, some accessibility obstacles only become evident when testing in an environment that matches the experience of the challenged user. I have seen many pages that looked great in IE but were unusable in lynx or Jaws or other software used for alternative access to web content. Never mind Firefox–is the U.S. Copyright Office leaving these people behind? If they’re only going to test in IE, are they really going to turn off images and test tab order on every page they develop? Are they truly going to validate each page (because regardless of other design issues, if you don’t start with valid code, many tools designed for accessible access are completely defeated)? Or can they now say, “We asked the public, and they said LGTM was ok by them?”

I wonder if they read the draft 2.0 WAI guidelines, and noted that for “government agency [that publish] information intended for the general public,” “The specified baseline includes only technologies that have been widely supported by more than one accessible and affordable user agent for more than one release.” Is the Copyright Office thumbing its nose at the W3C?

Then there is the issue of “do as we say, not as we do.” Many government agencies are required to make their facilities and services accessible. This doesn’t apply to the Copyright Office?

Or, to be kinder, perhaps they want to give the heave-ho to Siebel (the vendor producing the software that generates the pages), or shame them into including more reasonable testing standards in their bids for this job, and they need public comments to support the decision. Perhaps this is wish fulfillment, but I sense a hint of resistance to LGTM in this statement:

“More generally, in the interest of achieving support for browsers in the Office’s preregistration processing environment, this notice inquires whether (and why) an eligible party who anticipates preregistering a claim on the electronic-only form will not be able to use Internet Explorer to do so, or will choose not to preregister if it is necessary to use Internet Explorer.”

Perhaps the Copyright Office wants to do the right thing, and needs our help. Perhaps we can help them escape LGTM and produce an accessible website that can, within reasonable limits, serve as many people as possible.

I am drafting my letter, and I am carboning a raft of organizations who share my concerns. Please join me in doing the analog-letter thing. Send the original and five copies of your comment to:

Copyright GC/ I&R
P.O. Box 70400
Southwest Station, Washington, DC

Send it by first-class snail mail; “Comments may not be delivered by means of overnight delivery services such as Federal Express, United Parcel Service, etc., due to delays in processing receipt of such deliveries.”

I’ll post my letter tomorrow.

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