For Approval: IPA Font License v1.0

Bruce Perens bruce at
Wed Feb 4 20:41:46 UTC 2009

Hi Yuko-san,

Your project is very interesting, congratulations! I do see some
problems with the license that I hope you can work through.

One of the main purposes of Open Source is to encourage the distribution
of derived works, so that Open Source programs can be extended and
improved in perpetuity. Thus, I see a problem with your statement:

> Modifications and adjustments may be conducted freely for personal use.

Although this is not quite what the license itself says, the license
does seem to be intended to make modifications for other than personal
use difficult. The intent of Open Source is that modifications for any
sort of use - not just personal use - must will be allowed.

The problem I see with your license is that it does not allow the
distribution of derived works as font files, only as difference files.
Presumably each user would have to combine the font and the difference
file to create a new font on the end user's system. And that font could
never be distributed in its usable form. This does not seem very
practical. At a minimum, your license should allow for the distribution
of derived works as font files. Although the Open Source Definition
allows the distribution of source-code modifications as difference
files, it does not make any such provision for the program in its
executable form.

By restricting the distribution of derived works to difference files,
the license also makes it an act of infringement to convert the font
file to another file format. For example, the conversion from a Type One
font to an SVG Font is not allowed by the license. This also seems
impractical and overly restrictive.

I do not believe that there is significant danger to the font users from
the distribution of "unapproved" versions, as long as those versions are
named differently from the original (as your license requires). Our
experience in Open Source has been that allowing people to change things
invariably makes them better. Deliberately improper modifications have
been very rare - I can only think of a few in the last 10 years. They
are very quickly found and eliminated.

I hope you can resolve these issues.

Many Thanks

Bruce Perens

yuko.noguchi at wrote:
> Dear OSI members:
> On behalf of The Information-Technology Promotion Agency, Japan ("IPA"), we would like to submit "IPA Font License v1.0" for OSI approval.
> The full text of the license can be found at the following URL:
> The following are some basic facts regarding IPA, history of this license and the reason why we ask for OSI approval.
> [About IPA]
> The following website is about IPA (The Information-Technology Promotion Agency, Japan):
> For information about the Open Software Center that manages the IPA Font please refer to the following website:
> [IPA Font License History and Rationale for OSI  Compliance]
> 1.  The IPA Font
> As the Japanese government worked to promote the popularization of open source software (“OSS”), it became clear that no Japanese-language font existed that could be freely used in an OSS development environment or in a multi-OS (operating system) environment.  The lack of an open Japanese-language font was a significant obstacle for the promotion of OSS and for the stimulation of Japan’s software industry.
> 2.  The Creation of IPA Font and the Current IPA Font License 
> Recognizing that a Japanese-language font was important to ensure future intercompatibility of Japanese-language electronic documents for software research and development in Japanese-language environments, the high quality Japanese “IPA Font”, to which IPA holds all rights, was created on December 18, 2003.  This IPA Font includes 7,000 characters per typeface, complying with Japanese industry standard (JIS) X 0208:1997.  In October, 2007, a license  was prepared in compliance with JIS X 0213:2004 (12,000 characters per typeface) (the "Current License").
> The Current License under which the IPA Font Ver. 2 is distributed was prepared based on the following policies.
> (1) The highest degree of freedom is granted for general users to use the font for digital content.
> (2) Modifications and adjustments may be conducted freely for personal use.
> (3) The IPA Font provided may be distributed freely.  However distribution restrictions apply to derivative fonts created by modification adjustment or extraction of the IPA Font.  
> 3.  License Revision and the Reason for Asking OSI Approval
> There is a plan to release a new OTF (output text format) version of the IPA Font.  The aim is to enable the community to enjoy an open development structure and open utilization of the IPA Font and to create an internationally coherent license system.  This is significant because the IPA Font is becoming established as the standard public font supporting Japan’s software infrastructure.  Maintenance of the font’s quality and extensive use of the font will lead to greater interoperability, which we anticipate will in turn lead to the promotion of innovations in the software industry.  
> Enhancing interoperability can be achieved in an effective manner by bundling fonts to operating systems.  However, many distributors require OSI approval of its license as part of their bundling policy. 
> 4.  Significance of the IPA Font License
> We have therefore prepared an open font license, which we have submitted for your review today, to comply with OSD, considering the special characteristics of a Japanese-language font and the special characteristics of the Japanese-language font industry.  By obtaining OSI approval, the Japanese-language font will play an important role as an open module in OSS and in the rest of the software industry.  A Japanese-language font is essential in Japanese-language environment infrastructure.  A new license that can further promote the IPA Font as an open font is considered to have great social significance by becoming a foundation for future development of the software industry.
> We hope that this license will result in a software development environment with a high level of interoperability and the promotion of innovation in the Japanese software industry.  
> Thank you for your time and efforts to review the IPA Font License v1.0.
> Sincerely, 
> ======================
> Yuko Noguchi
> Toby Stephens
> Attorney-at-Law
> Marunouchi Kitaguchi Building
> 1-6-5 Marunouchi Chiyoda-ku
> Tokyo, Japan
> Tel: +81-3-5223-7761
> Fax: +81-3-5223-7661
> URL:

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