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I have just finished reading the article you published today on the Hastings Research website, authored by Norman Goundry, entitled "Why Unicode Won't Work on the Internet: Linguistic, Political, and Technical Limitations."

Mr. Goundry's grounding in Chinese is evident, and I will not quibble with his background East Asian historical discussion, but his understanding of the Unicode Standard in particular and of the history of Han character encoding standardization is woefully inadequate. He make a number of egregiously incorrect statements about both, which call into question the quality of research which went into the Unicode side of this article. And as they are based on a number of false premises, the article's main conclusions are also completely unreliable.

Here are some specific comments on items in the article which are either misleading or outright false.

Before getting into Unicode per se, Mr. Goundry provides some background on East Asian writing systems. The Chinese material seems accurate to me. However, there is an inaccurate statement about Hangul: "Technically, it was designed from the start to be able to describe any sound the human throat and mouth is capable of producing in speech, ..." This is false. The Hangul system was closely tied to the Old Korean sound system. It has a rather small number of primitives for consonants and vowels, and then mechanisms for combining them into consonantal and vocalic nuclei clusters and then into syllables. However, the inventory of sounds represented by the Jamo pieces of the Hangul are not even remotely close to describing any sound of human speech. Hangul is not and never was a rival for IPA (the International Phonetic Alphabet).

In the section on "The Inability of Unicode To Fully Address Oriental Characters", Mr. Goundry states that "Unicode's stated purpose is to allow a formalized font system to be generated from a list of placement numbers which can articulate every single written language on the planet." While the intended scope of the Unicode Standard is indeed to include all significant writing systems, present and past, as well as major collections of symbols, the Unicode Standard is not about creating "formalized font systems", whatever that might mean. Mr. Goundry, while critiquing Anglo-centricity in thinking about the Web and the Internet as an "unfortunate flaw in Western attitudes" seems to have made the mistake of confusing glyph and character -- an unfortunate flaw in Eastern attitudes that often attends those focussing exclusively on Han characters.

Immediately thereafter, Mr. Goundry starts making false statements about the architecture of the Unicode Standard, making tyro's mistakes in confusing codespace with the repertoire of encoded characters. In fact the codespace of the Unicode Standard contains 1,114,112 code points -- positions where characters can be encoded. The number he then cites, 49,194, was the number of standardized, encoded characters in the Unicode Standard, Version 3.0; that number has (as he notes below) risen to 94,140 standardized, encoded characters in the current version of the Unicode Standard, i.e., Version 3.1. After taking into account code points set aside for private use characters, there are still 882,373 code points unassigned but available for future encoding of characters as needed for writing systems as yet unencoded or for the extension of sets such as the Han characters.

Even if Mr. Goundry's calculation of 170,000 characters needed for China, Taiwan, Japan, and Korea were accurate, the Unicode Standard could accomodate that number of characters easily. (Note that it already includes 70,207 unified Han ideographs.) However, Mr. Goundry apparently has no understanding of the implications or history of Han unification as it applies to the Unicode Standard (and ISO/IEC 10646). Furthermore, he makes a completely false assertion when he states that Mainland China, Taiwan, Korea, and Japan "were not invited to the initial party."

Starting with the second problem first, a perusal of the Han Unification History, Appendix A of the Unicode Standard, Version 3.0, will show just how utterly false Mr. Goundry's implication that the Asian countries were left out of the consideration of encoding of Han characters in the Unicode Standard is. Appendix A is available online, so there really is no valid research excuse for not having considered it before haring off to invent nonexistent history about the project, even if Mr. Goundry didn't have a copy of the standard sitting on his desk. See:

http://www.unicode.org/unicode/uni2book/appA.pdf

The "historical" discussion which follows in Mr. Goundry's account, starting with "The reaction was predictable ..." is nothing less than fantasy history that has nothing to do with the actual involvement of the standardization bodies of China, Japan, Korea, Taiwan, Hong Kong, Singapore, Vietnam, and the United States in Han character encoding in 10646 and the Unicode Standard over the last 11 years.

Furthermore, Mr. Goundry's assertions about the numbers of characters to be encoded show a complete misunderstanding of the basics of Han unification for character encoding. The principles of Han unification were developed on the model of the main Japanese national character encoding, and were fully assented to by the Chinese, Korean, and other national bodies involved. So assertions such as "they [Taiwan] could not use the same number [for their 50,000 characters] as those assigned over to the Communists on the Mainland" is not only false but also scurrilously misrepresents the actual cooperation that took place among all the participants in the process.

Your (Mr. Carroll's) editorial observation that "It is only when you get all the nationalities in the same room that the problem becomes manifest," runs afoul of this fantasy history. All the nationalities have been participating in the Han unification for over a decade now. The effort is led by China, which has the greatest stakeholding in Han characters, of course, but Japan, Korea, Taiwan and the others are full participants, and their character requirements have not been neglected.

And your assertion that many Westerners have a "tendency .. to dismiss older Oriental characters as 'classic,'" is also a fantasy that has nothing to do with the reality of the encoding in the Unicode Standard. If you would bother to refer to the documentation for the Unicode Standard, Version 3.1, you would find that among the sources exhaustively consulted for inclusion in the Unicode Standard are the KangXi dictionary (cited by Mr. Goundry), but also Hanyu Da Zidian, Ci Yuan, Ci Hai, the Chinese Encyclopedia, and the Siku Quanshu. Those are the major references for Classical Chinese -- the Siku Quanshu is the Classical canon, a massive collection of Classical Chinese works which is now available on CDROM using Unicode. In fact, the company making it available is led by the same man who represents the Chinese national standards body for character encoding and who chairs the Ideographic Rapporteur Group (the international group that assists the ISO working group in preparing the Han character encoding for 10646 and the Unicode Standard).

Mr. Goundry's argument for "Why Unicode 3.1 Does Not Solve the Problem" is merely that "[94,140 characters] still falls woefully short of the 170,000+ characters needed"-- and is just bogus. First of all the number 170,000 is pulled out of the air by considering Chinese, Japanese, and Korean repertoires without taking Han unification into account. In fact, many more than 170,000 candidate characters were considered by the IRG for encoding -- see the lists of sources in the standard itself. The 70,207 unified Han ideographs (and 832 CJK compatibility ideographs) already in the Unicode Standard more than cover the kinds of national sources Mr. Goundry is talking about.

Next Mr. Goundry commits an error in misunderstanding the architecture of the Unicode Standard, claiming that "two separate 16-bit blocks do not solve the problem at all." That is not how the Unicode Standard is built. Mr. Goundry claims that "18 bits wide" would be enough -- but in fact, the Unicode Standard codespace is 21 bits wide (see the numbers cited above). So this argument just falls to pieces.

The next section on "The Political Significance Of This Expressed In Western Terms" is a complete farce based on false premises. I can only conclude that the aim of this rhetoric is to convince some ignorant Westerners who don't actually know anything about East Asian writing systems -- or the Unicode Standard, for that matter -- that what is going on is comparable to leaving out five or six letters of the Latin alphabet or forcing "the French ... to use the German alphabet". Oh my! In fact, nothing of the kind is going on, and these are completely misleading metaphors.

The problem of URL encodings for the Web is a significant problem, but it is not a problem *created* by the Unicode Standard. It is a problem which is being actively worked on my the IETF currently, and it is quite likely that the Unicode Standard will be a significant part of the solution to the problem, enabling worldwide interoperability, rather than obstructing it.

And it isn't clear where Mr. Goundry comes up with asides about "Ascii-dependent browsers". I would counter that Mr. Goundry is naive if he hasn't examined recently the internationalized capabilities of major browsers such as Internet Explorer -- which themselves depend on the Unicode Standard.

Mr. Goundry's conclusion then presents a muddled summary of Unicode encoding forms, completely missing the point that UTF-8, UTF-16, and UTF-32 are each completely interoperable encoding forms, each of which can express the entire range of the Unicode Standard. It is incorrect to state that "Unicode 3.1 has increased the complexity of UCS-2." The architecture of the Unicode Standard has included UTF-16 (not UCS-2) since the publication of Unicode 2.0 in 1996; Unicode 3.1 merely started the process of standardizing characters beyond the Basic Multilingual Plane.

And if Mr. Goundry (or anyone else) dislikes the architectural complexity of UTF-16, UTF-32 is *precisely* the kind of flat encoding that he seems to imply would be preferable because it would not "exacerbate the complexity of font mapping".

In sum, I see no point in Mr. Goundry's FUD-mongering about the Unicode Standard and East Asian writing systems.

Finally, the editorial conclusion, to wit, "Hastings [has] been experimenting with workarounds, which we believe can be language- and device-compatible for all nationalities," leads me to believe that there may be hidden agenda for Hastings in posting this piece of so-called research about Unicode. Post a seemingly well-researched white paper with a scary headline about how something doesn't work, convince some ignorant souls that they have a "problem" that Unicode doesn't address and which is "politically explosive", and then turn around and sell them consulting and vaporware to "fix" their problem. Uh-huh. Well, I'm not buying it.