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Letter to Malcolm Johnson on ITU databases

04 February 2010

DIGITALEUROPE and its member companies remain deeply concerned by the direction of the ITU in this matter. While we are sympathetic to the challenges faced by developing countries as they seek to upgrade their current infrastructure, we are opposed to any solutions including "Resolution 76", which create barriers to trade, delay market access, increase costs, and stifle innovation.

Consequently, we urge ITU to suspend the implementation of the ITU conformity and interoperability databases. We suggest that the ITU conduct a thorough analysis of the business benefits of such a program for the ITU and equipment manufacturers. The analysis should be balanced to include the costs and potential liabilities together with any measurable benefits. Particular attention should be given to illustrate the benefits of ITU recommendation compliance to resolve specific problems encountered by developing countries. The analysis should also take into account the incomprehensive nature of an ITU database given the numerous other standards bodies such as IEEE, IETF, WiMAX Forum, OIF or MEF interoperability agreements which govern relevant equipment choices for developing countries. Without such a thorough analysis, we believe that there can be no legitimate justification for creating such a database.

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