This is in response to a request for comments on the 7 September version of the DMM. However, we will limit our comments to the sections that discuss interoperable DRM, since this is where, I think, our comments will be most relevant.

We agree wholeheartedly with your assertions about the DRM landscape, and the so-called "stalemate" that exists between content owners, the technology providers, and consumers. We have felt that part of the problem with DRM has been it's constant "we own it" mind-set. Seeing the obvious market potential, all vendors, up to now, have positioned their solution as the only one, vigorously asserting IP in all aspects of the value chain. Unfortunately, all this succeeded in doing was retarding the growth of this
nascent market opportunity. (Microsoft is the only company that can set
standards in this manner and they succeed by offering workable toolsets and extremely low prices. They are now seeing the fruits of their labor; many companies we know of are utilizing the WM SDKs since they are really the only working DRM software base available right now).

As you point out, the "social damage" from the DM stalemate is actually quite profound. Millions have been wasted on costly court proceedings and failed technology trials; all, essentially predicated on finally being the one individual or company who would provide the single answer to the problem. These machinations have only contributed to the media spin and technology churn that has become the DRM industry which, astonishingly enough, has yet to produce a low-cost, widely available suite of software services that actually would enable it. Having been involved in the technical implementation of two major digital media trials (Project Nigel and Napster), we have seen the hubris and eventual disillusionment that have come from attempting to own a market that is far too large and complex for one or a relative few.

However, as you state, there is simply "too much at stake" to sit idly by and watch this happen. This was the impetus for OpenIPMP and our reason for joining MOSES in Europe (financial issues have forced us to scale back our involvement of late, however we maintain close ties to the current members). OpenIPMP is a simple working DRM model, built from freely available components, utilizing open standards where possible. We have no agenda (or funding:)) for it other than for it to be for all developers to use, regardless of their financial situation or corporate affiliation. Please note however, that we are definitely not against IP protection, and believe that this is the best model to stimulate innovation. We firmly believe that IP holders should appreciate licensing fees, where appropriate. We are, however, against licensing restrictions that are discriminatory or are considered exhorbitant by the software community.

We believe in your vision and want to help in any way we can (we are a small firm with limited resources, unfortunately). Please let us know how we can be of assistance in the upcoming specifications process.