For Approval: IPA Font License v1.0

[yuko.noguchi at mhmjapan.com]

Dear Bruce and all,

Thank you for your comments.  Let us address these in turn.
 
1.  Personal Use
First of all, we do agree that it is important to provide a convenient
environment for developing free fonts in the Japanese Open Source
market.  The Personal Use restriction is not a part of IPA policy
anymore, and the proposed license has been redrafted in accordance with
the Open Source principles.
 
2.  Difference Files
To understand IPA's perspective, it is worth considering the environment
surrounding the use and development of the Japanese font industry and
where this may differ from the US font industry.
Fundamental is the difference between a font program ("FP") for an
alphabet or "phonogram" based language (English) and Japanese which is
Kanji or "ideogram" based.  The latter comprises over 10,000 distinct
and different characters.  In many cases the difference between
completely unrelated characters is very small.   Even a very slight
change to the construction of such a character may  result in
misdescription, or in a worst case scenario, its mistaken conversion to
a character with a completely different meaning.  Please see an example
of one Kanji character, the unified ideograph U+82A6 "ashi" explained in
Section B.1 and B.2 in an article which can be found at the following
URL: http://www.unicode.org/reports/tr37/ .  This is a small example of
what is a very real problem.  It is often very difficult to modify font
program without making such mistakes when there are many similar Kanji
characters.

Therefore, IPA thinks it very important to be clear about exactly what
modifications have been applied in creating the Derivative FP.  Further
it is important that the Original FP is preserved and immediately
accessible to ensure that any developer or user can refer to that
Original FP as a reference to confirm the character selection in case of
doubt.  By always referencing any derivative works back to  and creating
any Derivative FP's directly from the Original FP there is less chance
that mistakes can become compounded and perpetuated.  In this way, it
would be easier for the developers of fonts to correct any problems and
to maintain font integrity.  In a FP consisting of over 10,000
characters with small differences only, this is an important and
difficult task.
 
This is really the core reason why we have submitted the IPA Font
License - As  a  license which falls within the Open-Source fundamentals
and also reflects the circumstances of Kanji-based languages as in Japan
and China.  IPA  believes that the proposed difference file system is
fundamental to achieving a robust open-source environment for the free
development distribution and use of the Kanji based fonts.  Since the
OSD allows such a mechanism, we are keen and willing to do the work to
create a license that meet both (i) IPA's belief in this Difference File
system as preserving integrity and (ii) the OSD requirements.
 
 
We are informed by IPA that the combination of the Original FP and the
Difference File is an extremely easy operation which is fully automated
if  authorized by the user.  This should therefore present no bar to
end-users.
 
3.  Conversion to another file format.
IPA considers that a difference file system can easily be applied to the
Original FP to  convert the font file to another file format.  This
should therefore allow such conversion without any infringement of the
proposed license. Also, the SVG Font format is allowed, as SVG is used
in embedding fonts to a Digital Document File, and the license expressly
allows to embed the Licensed Program into a Digital Document File.
 
 
We hope that this is a useful clarification of the spirit in which the
license is intended.  We are grateful for your further comments and
thoughts to help us achieve an appropriate Open Source friendly license.
 
Kind regards,

Yuko Noguchi