Subject: Responses to comments on ISO Committee Draft 2108, International Standard Book Number (ISBN)

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1 ISO/TC 46/SC 9 Secretariat Library and Archives of Canada 395 Wellington Street Ottawa, CANADA K1A 0N4 ISO/TC 46/SC 9 Secrétariat Bibliothèque et archives du Canada 395, rue Wellington Ottawa, CANADA K1A 0N4 Telephone - Téléphone (819) Fax : (819) Internet: iso.tc46.sc9@nlc-bnc.ca Web site: < To: Voting members (P-members) of ISO TC 46/SC 9 ISO TC 46/SC 9/Working Group 4 Selected organizations in liaison ISO TC 46/SC 9 N 360 [supercedes document N 352] cc. ISO TC 46 Secretariat ISO Central Secretariat Subject: Responses to comments on ISO Committee Draft 2108, International Standard Book Number (ISBN) The attached document shows the disposition of comments on ISO Committee Draft 2108 for the the revision of the International Standard Book Number (ISBN). The results of voting and comments on CD 2108 were distributed in May 2003 as TC46/SC9 document N 353. ISO/TC 46/SC 9 Working Group 4 discussed the comments on CD 2108 at its meeting in Rome on May 19-20, The attached document shows WG 4's agreed responses to those comments. The accompanying revisions to CD 2108 are shown separately in SC 9 document N 361. WG4 presented its responses to the SC9 meeting on May 21, 2003 where SC9 resolved that Committee Draft 2108, as modified by the decisions of the WG 4 meeting, would advance to the Approval stage for voting as ISO Draft International Standard 2108 (see N 359, resolution 1). ACTION REQUESTED: ONLINE VERSION: Retain this document for future reference when DIS 2108 is distributed for voting. Target date for DIS distribution: September or October This document is also available on the ISO/TC 46/SC 9 Web site at: < With regards, [original signed by] Jane Thacker Secretary, ISO/TC 46/SC 9 ISO International Organization for Standardization ISO Organisation internationale de normalisation TC 46 Information and Documentation TC 46 Information et documentation SC 9 Identification and Description SC 9 Identification et description

2 TABLE OF REPLIES ISO Committee Draft 2108, International Standard Book Number (ISBN) ISO/TC46/SC9 N 360 P-Members of ISO/TC46/SC9 Agree to register as DIS Disagree Abstain Did not reply Comments submitted Australia (SAI) SAI SAI Bulgaria (BDS) BDS -- Canada (SCC) SCC SCC China, P.R. (CSBTS) CSBTS Colombia (ICONTEC) ICONTEC ICONTEC Czech Republic (CSNI) CSNI CSNI Denmark (DS) DS -- Finland (SFS) SFS SFS France (AFNOR) AFNOR -- Germany (DIN) DIN DIN Hungary (MSZT) MSZT MSZT Italy (UNI) UNI -- Japan (JISC) JISC -- Kenya (KEBS) Netherlands (NEN) KEBS NEN Norway (NSF) NSF NSF Poland (PKN) Portugal (IPQ) PKN Russian Fed. (GOST R) GOST R GOST R South Africa (SABS) Spain (AENOR) SABS IPQ AENOR Sweden (SIS) SIS SIS U.K. (BSI) BSI BSI U.S.A. (ANSI) ANSI ANSI TOTAL (of 24) OTHERS: Thailand (approval, no comments); International Booksellers Federation

3 ISO/TC 46/SC 9 N 360 page 3 RESPONSES TO COMMENTS ON ISO COMMITTEE DRAFT 2108 as agreed at the ISO TC46/SC9 WG 4 meeting in Rome, May 19-20, 2003 GENERAL COMMENTS: SIS (Sweden) The Swedish centre for ISBN is organized within the Royal Library of Stockholm as part of its department Collection Development & Documentation. The centre has discussed the CD with the Swedish representative in the working group and accepts the text as it stands in all parts. The only negative comment we want to propose is the following [see SIS comment on the definition of edition at 3.4, below]. On the other hand, the centre welcomes the libreral and understanding approach to bibliographic service illustrated by clause E.3 [Association of an ISBN with ISBN metadata]. SCC (Canada) Before or in conjunction with the next voting stage on this standard, additional guidance must be provided regarding the implementation of these changes. For example, Annex F gives the impression that all 10-digit ISBN should be converted to 13 digits as of the implementation date. Would that also affect ISBN in existing MARC records (i.e., in library databases)? We assume that is not the intention but, clearly, a broader range of implementation issues covering more than just trade applications must be addressed in Annex F.4 before this standard is approved. Libraries probably have a larger "legacy" of ISBN than any other sector of the information supply chain and their specific context and concerns must be addressed in implementation guidelines. System vendors will also need to be made aware of the fact that the new check digit algorithm is completely different from the old one, and that X is no longer a valid checkdigit. If 10 and 13 digit ISBN can co-exist in a database (e.g. in MARC records), any system that is used to validate those numbers will need to be capable of processing either form of ISBN. WG RESPONSE: Agreed. Detailed implementation guidelines will be available before the DIS is issued. NSF (Norway) COMMENT: Positive to metadata. COMMENT: It is a general agreement that different online formats should be allocated different ISBNs. But there are two questions:

4 page 4 1. It seems as if ISSN does not allocate different ISSNs to different formats (source: The ISSN meeting 2002). Why do ISSN and ISBN have different rules? WG RESPONSE: It is legitimate for different rules to apply to different standards. The ISBN identifies individual products; ISSN is assigned at the title level. 2. What about free digital (scanned) reproductions of printed publications? Are they new editions? (See also the ISSN manual final draft, Note). [For information Note 2.2 from the ISSN manual reads as follows: "Micro and digital reproductions produced for the purpose of providing surrogates for the original materials are the exception and shall use the ISSN of the original continuing resources."] WG RESPONSE: The issue is whether the organization involved is acting as a publisher. On that basis, reproductions for internal purposes should not be treated as new editions. This is covered in clause 3.7 by defining a monographic publication, for the purposes of ISBN, as something that is "made available to the public". International Booksellers Federation [From the IBF Secretariat]: I have circulated your document among EBF and IBF Members and I am happy to report that there is a general agreement that globally speaking the revisions seem to be well thought and that rules are clear. [Accompanied by comments from the President of the European Booksellers Federation, see relevant clauses below] SFS (Finland) COMMENT: It is required that the change from the 10 digit ISBN to the 13 digit one will guarantee that the new ISBN numbers will last over 50 years. WG RESPONSE: This is not appropriate to include in the standard. However the new syntax of the ISBN does accommodate additional expansion of the numbering capacity when necessary. COMMENT: The transitional stage of the 13 digit ISBN will cause additional work for book stores and book wholesalers as well as the changes in the different data systems. COMMENT: The book branch feels a bit confusing with the two different ISBNs in new book registers during the transitional stage. That is why exact instructions are needed. WG RESPONSE: Additional implementation guidance is being developed.

5 SPECIFIC COMMENTS ARRANGED BY CLAUSE NUMBER Introduction SCC (Canada) ISO TC 46/SC 9 N 360 page 5 The standard never actually states why the 978 and 979 prefixes are being incorporated within the ISBN syntax and how that will increase the number of available ISBN. While it may seem obvious, our reviewers felt that the reason for making a change of this magnitude should be recorded somewhere in the text of the ISBN standard. We suggest adding this information to the Introduction. Perhaps some text could be extracted for this purpose from the set of "Frequently Asked Questions" on the project's Web site. WG RESPONSE: This explanation has been given in the Foreword. 1 Scope BSI (United Kingdom) See U.K. comment on 3.4 (below), proposing the phrase "product form or edition" instead of "format or edition". WG RESPONSE: The term "product form" will be used. This term will be adopted throughout the standard, wherever appropriate. NSF (Norway) Clause 1, paragraph 1: COMMENT: It is not clear what is meant by descriptive information (metadata). Descriptive data may also mean the administrative datas, not only the metadatas as we use the term in the standard. Maybe metadata and adminstrative data should be defined? PROPOSED CHANGE: ( ) the metadata to be associated with the ISBN allocation ( ) WG RESPONSE: The decision at the meeting was to delete the phrase descriptive information and use "metadata". Possible definitions of metadata were to be investigated. NOTE FROM THE SC9 SECRETARIAT: ISO's editing directives state that "Common dictionary or current technical terms shall be included only if they are used with a specific meaning in the relevant context". "Metadata" is a current technical term that is being used in its conventional sense in the ISBN standard. Furthermore, the ISO standard for Dublin Core metadata does not include a definition of

6 page 6 "metadata". For these reasons, the Secretariat suggests that there is no need for the ISBN standard to include its own definition of "metadata". For the record, here are the two ISO definitions of "metadata" that were found: -- metadata: Data that is included in an entity or linked to an entity that describes the entity and assists in its retrieval. [Source: ISO , "Information and documentation Bibliographic data element directory Part 5: Data elements for the exchange of cataloguing and metadata"] -- metadata: Data that defines and describes other data. [Source: ISO/IEC :1999, "Information technology -- Specification and standardization of data elements -- Part 1: Framework for the specification and standardization of data elements] MSZT (Hungary) 1 Scope: This is the first place where the term metadata is used in the draft. We know that this term is widely used for descriptive and informative data on (first of all electronic) documents. However, our opinion is, that this term is rather general and does not express the content and purpose of these data. The correct term would be descriptive information. This comment will not be repeated when the term metadata appears in the text. See also our comments on Annex E. WG RESPONSE: See above response to NSF comment. SFS (Finland) 1 Scope COMMENT: We suggest that the BICI system ought to be mentioned as an alternative for numbering individual sections or chapters of the monographic publications. Maps should not be mentioned because they also have been removed from the Annex A. Examples of other products to which ISBN is applicable have been given in the Annex A and there is no need to repeat the list in the Scope chapter. PROPOSED CHANGE: Proposed new formulation of the second and third paragraphs: This International Standard is applicable to monographic publications (or their individual sections or chapters where these are made separately available, this type of usage of ISBN is an alternative for using BICI (Book Item and Component Identifier) once that identifier has been established) and certain types of related products. Details concerning the scope of ISBN and examples of applicable and non-applicable products are provided in Annex A. WG RESPONSE: The SFS comment about BICI was withdrawn at the meeting.

7 page 7 The examples in the second paragraph were deleted and the reference to Annex A in the 3 rd paragraph was appended to the 2 nd paragraph of the Scope. 3 Definitions SCC (Canada) [See SCC comment on Annex A.3, below.] We also note that the definition of a series was deleted from clause 3 when the final Working Draft (WG4 N26) was prepared as a Committee Draft. In its place we propose a simpler definition of "series", based on a definition in the Anglo-American Cataloguing Rules: series: A group of separately available publications related to one another by the fact that each of them bears, in addition to its own individual title, a collective title applying to the group as a whole. The individual items may or may not be numbered. WG RESPONSE: Comment was withdrawn by SCC at the meeting. NSF (Norway) Clause 3: COMMENT: We miss a definition of e-book and of internet publication. WG RESPONSE: No change. ISO's editing directives state that "Common dictionary or current technical terms shall be included only if they are used with a specific meaning in the relevant context". That does not apply in the case of these terms. SFS (Finland) 3 Term(s) and definition(s) COMMENT: definitions for terms publisher, producer and product should be provided to ensure sufficient clarity. WG RESPONSE: No change. ISO's editing directives state that "Common dictionary or current technical terms shall be included only if they are used with a specific meaning in the relevant context". That does not apply in the case of these terms. However, SFS is invited to suggest definitions, if desired, for possible inclusion in the Users' Manual.

8 page ("EAN.UCC prefix") [N.B.: Also see comments on clause 4.2, below.] DIN (Germany) COMMENT: While the explanation of "EAN.UCC prefix is completely correct the standard only deals with those prefixes hidden in the small print note. These are currently called Bookland/EAN, a term that has been used in the ISBN community for almost 20 years. Is there any need for changing this? If EAN.UCC prefix is considered preferable, then it should be used in the text as: EAN.UCC prefixes allocated solely for the use of the ISBN system and made available through the International ISBN Agency. Otherwise it may be very confusing in practice, and some publishers will use the country prefixes, or only regular EAN.UCC article numbers. PROPOSED CHANGE(S): EAN.UCC prefixes allocated solely for the use of the ISBN system and made available through the International ISBN Agency The (continued) use of EAN/Bookland is proposed: EAN/Bookland an international 3 digit product number prefix made available by EAN International for the sole use in the ISBN system. WG RESPONSE: See response to the Canadian comment on clause 4.2, below. It was also noted that particular attention will have to be given to the Japanese JAN code in the Users' Manual and implementation guidelines. The JAN is Japan's version of the EAN prefix and a JAN may include additional information such as price. 3.3 (definition of continuing resource): CSNI (Czech Republic) In the note dealing with serials yearbooks and monographic series to which ISBN is assigned are not mentioned (see also CSNI comment on A.1.10, below). WG RESPONSE: Clause 3.3 is not intended as an exhaustive list of applicable publications. More details will be provided in the Users' Manual. There is no definition of electronic publications. WG RESPONSE: No change. See response to NSF comment on clause 3, above. Is it really necessary to begin to use a new terminology instead of that being in use for thirty previous years (i.e., registrant instead of publisher, registration group instead of group agency

9 page 9 and further in the text: registration group element instead of group identifier, registrant element instead of publisher identifier, and publication element instead of title identifier)? WG RESPONSE: No change. SCC (Canada) Not all loose-leaf publications are continuing resources; some are regarded as finite publications and are eligible for ISBN. The problem is that the wording of the note to the definition at clause 3.3 can be misinterpreted. For perfect clarity, it ought to read: "Continuing resources include ongoing integrating resources such as loose-leaf publications that are continually updated and Web sites that are continually updated." WG RESPONSE: Agreed. The wording of clause 3.3. has been revised as proposed. MSZT (Hungary) 3.3 COMMENT: We know that nowadays the term "resources" is widely used instead the term documents. Probably the ISBD on electronic documents was the first case of using resources in the meaning of documents although it is absolutely clear from any standard definition of documents, that the meaning of document does not exclude electronic or any other documents recorded on any carrier. Probably it is to late but we however recommend the replacement of the term resources, by the term documents. WG RESPONSE: No change. The term "continuing resource" has already been widely adopted (e.g. by the ISSN Network, the ISBD, and AACR). 3.4 ("edition") SIS (Sweden) The definition of edition, 3.4, should be expanded and run as follows: edition: All copies of a publication embodying essentially the same content, derived from essentially the same act of registration, and issued by the same entity. WG RESPONSE: No change. BSI (United Kingdom) It would help if the note attached to the definition of "edition" contained the same text as that at "product form". It might also help to give examples: "A single edition of a publication may

10 page 10 be published in multiple forms, for example the same edition of a novel may appear in the product forms of paperback, hardback, cassette audiobook, CD audiobook, braille book etc." And I'd prefer here "multiple product forms" to "multiple forms" too. WG RESPONSE: The note formerly at 3.9 ("product form") was moved to 3.4 ("edition") and revised as: "Note A single edition of a publication may be published in multiple product forms." Examples will be added to 3.9 in place of its former note. Further, the "Scope" statement refers to "format or edition" - we suggest this should be aligned with the definitions sections to read "product form or edition". The same problem arises in A.1.2: "different formats" should be "different product forms". The same problem also arises in A.1.7. WG RESPONSE: The term "product form" has replaced "format" wherever appropriate throughout the standard. See response to BSI comment under Scope, above. GOST R (Russian Federation) Comment [accompanying abstention]: Some of the definitions are not clear enough. Alternative wordings are proposed below. 3.4 edition - All copies of a publication embodying the same content and by the same entity at the same time. WG RESPONSE: No change. All copies of an edition are not necessarily produced at the same time. 3.5 ("integrating resource") GOST R (Russian Federation) Comment [accompanying abstention]: Some of the definitions are not clear enough. Alternative wordings are proposed below. 3.5 integrating resource - A publication that integrates into the whole some previous publications or one previous publication with subsequent additions and/or updates to them. WG RESPONSE : No change. The existing definition is more in line with the definition adopted by the ISSN system. 3.7 ("monographic publication") DIN (Germany) COMMENT: 3.7 offered for general distribution. Whether a publication is a monograph or not, has no connection with its distribution. Also, for the purpose of ISBN allocation, distribution should not be an important criteria.

11 page 11 PROPOSED CHANGE: It is proposed to delete offered for general distribution. WG RESPONSE: The wording "made available to the public" will be used instead. MSZT (Hungary) 3.7 COMMENT: We recommend to insert the word finite before the word number ( within a finite number of parts ) for a better distinction from serials. PROPOSED CHANGE: A publication conceived as a whole in one part or within a finite number of parts by publisher/author(s( and offered for general distribution in any product form. WG RESPONSE: The word "finite" will be added to the definition. Also see response to DIN comment, above. The definition (now numbered 3.8) reads: "monographic publication: Publication conceived as a whole in one part or within a finite number of partes by its publisher/author(s) and made available to the public in any product form." GOST R (Russian Federation) Comment [accompanying abstention]: Some of the definitions are not clear enough. Alternative wordings are proposed below. 3.7 monographic publication - A publication conceived as a whole in one part or within a predetermined number of parts by publisher/author(s). WG RESPONSE: See response to MSZT comment above. SFS (Finland) 3.7 monographic publications COMMENT: The word finite is needed to be in accordance with the definitions of continuing resource and integrating resource. PROPOSED CHANGE: A publication conceived as a whole in one part or within a finite number of parts by publisher/author(s) and offered for general distribution in any product form WG RESPONSE: See response to MSZT comment above.

12 page ("product form") ANSI / NISO (U.S.A.) Section 3 Terms and definitions The term "Product form" requires further clarification to explain the expected level of granularity. If a publisher issues a talking book as regular audio tape, digital audio tape, CD- Audio, CD-ROM, DVD-ROM, DVD-Audio, DVD-RAM, MP3 file, WAV file, etc., how many different ISBNs will be assigned? WG RESPONSE: If the intention is that a particular format of an item will be made separately available for trade then it will require its own ISBN. See clause 5.5. MSZT (Hungary) 3.9 COMMENT: We recommend the wording medium and/or data instead of medium or data PROPOSED CHANGE: "The size, binding, medium and/or data structure of a publication" WG RESPONSE: See response to GOST R comment, below. GOST R (Russian Federation) Comment [accompanying abstention]: Some of the definitions are not clear enough. Alternative wordings are proposed below. 3.9 product form - The size, binding, medium or data format of a publication. WG RESPONSE: The definition was changed to: "The size, binding, medium and/or data format of a publication." Examples were added for further clarification. SFS (Finland) 3.9 Product form COMMENT: In 5.5, it should be made clear that product form also encompasses different formats of an electronic publication. Term document format should be defined as a specification of a document s data structure. WG RESPONSE: See above response to GOST R comment on this clause. COMMENT: A 1.3 and 1.7 should be synchronized with the specification in 5.5.

13 page 13 WG RESPONSE: The draft was reviewed to ensure consistency in the use of "product form" vs. "format" throughout the text. Clause 4.1 (General structure of an ISBN) CSNI (Czech Republic) After this text only hyphens are allowed for separation the elements of the ISBN; but further in the text (see Annex C, C.4) spaces are also mentioned. We should prefer the first possibility: separation only by hyphens. WG RESPONSE: Hyphens are the recommended approach. See response to ANSI/NISO comment, below. ANSI / NISO (U.S.A.) The standard must be explicit and consistent in its direction on the use of hyphens in display of the ISBN. Section 4.1 states that the hyphen "should" be used. Section C.4 states that hyphens "may" be used. It is suggest that "should" be used in Section C.4. WG RESPONSE: Agreed. The wording of Annex C.4 was changed to read "hyphens should be used ". An explanation of "human-readable form" was added in parentheses at clause 4.1 where the term is used for the first time: " in human readable form (i.e. a form meant primarily to be read or written by a person, in contrast to a form primarily meant to be used by data processing equipment)". MSZT (Hungary) 4.1 footnote 2 COMMENT: Instead of " inconjuction with " we recommend the text: corresponding to (according to the relevant conversion standard) " PROPOSED CHANGE: "In countries where the Latin alphabet is not used, the appropriate abbreviation for "International Standard Book Number" in the local script may be given corresponding to (according to the relevant conversion standard) the required letters ISBN in the Latin alphabet." WG RESPONSE: No change. It is important for global trade to ensure that the ISBN is always identified in the Latin alphabet, in addition to any local scripts.

14 page 14 Clause 4.2 (EAN.UCC prefix) [NOTE: Also see comments on clause 3.1, above.] SCC (Canada) The Committee Draft no longer uses the concept of the "Bookland EAN". Although we realize that EAN International is responsible for allocating the ISBN prefix, it should not do so arbitrarily. The Registration Authority must determine which of any reserved EAN.UCC prefixes are "active" for ISBN use at a given time. A valid ISBN should contain a prefix that has been authorized for ISBN use by the International ISBN Agency. We would also prefer a more generic heading for this clause, such as "Prefix element" or "Product number prefix". It is not necessary to name any of the component elements of an ISBN for the organization which originally allocated it. We propose changing the heading and content of clause 4.2 as follows: 4.2 Prefix element [or Product number prefix] The first element of a 13 digit ISBN shall be a 3 digit prefix specified by the International ISBN Agency in conformance with the global EAN.UCC product numbering system. This 3 digit prefix shall be reserved for ISBN purposes within the global EAN.UCC system. It indicates that the ensuing product number originates with and is part of the ISBN system. Technical information specifying valid EAN.UCC prefixes for ISBN use shall be available from the International ISBN Agency. If this change is accepted then the 1 st indent under clause 4.1 should also be changed to: "-- prefix element;" [or "-- Product number prefix"]. WG RESPONSE: The heading of clause 4.2 was changed to "Prefix element". The wording proposed by SCC was adopted with the following changes to the 1 st paragraph: "The first element of a 13 digit ISBN shall be a 3 digit prefix specified by the International ISBN Agency in conformance with the global EAN.UCC product numbering system. This prefix is made available to the International ISBN Agency by EAN International. It indicates that the ensuing 13 digit product number originates with and is part of the ISBN system." DIN (Germany) PROPOSED CHANGE: It is proposed to change this to: The first element of a 13 digit ISBN shall be the Bookland/EAN prefix. It shall be used to establish that the following identification number is an ISBN. Technical specifications shall be available from the International ISBN Agency.

15 page 15 WG RESPONSE: See response to SCC comment above. MSZT (Hungary) 4.2 COMMENT: We recommend to replace in the second paragraph the word establish by the word prove or any other appropriate word. No meaning of establish is adequate in the given context. PROPOSED CHANGE: "The EAN.UCC prefix shall be used to prove that the product number which follows is conformant with the ISBN sstem and is reserved for that purpose within the global EAN product numbering system." WG RESPONSE: See response to SCC comment, above. SFS (Finland) 4.2 EAN.UCC prefix COMMENT: The relationship between EAN International and ISBN organization should be declared in a separate Annex as well as the future cooperation with the new three digit EAN.UCC prefixes. WG RESPONSE: This matter will be addressed in separate governance procedures for the ISBN system. Contractual arrangements between EAN International and ISBN are not appropriate for the standard. COMMENT: Some clarifying remarks in a separate Annex about the planned usage of EAN.UCC prefixes 978 and 979 would be most helpful. WG RESPONSE: This is more suited to implementation guidelines. Matters such as when the "979" prefix comes into effect will be dealt with by the governing body of the ISBN system when the timing is appropriate. Clause 4.4 (Registrant element): DIN (Germany) COMMENT: 4.4 This element identifies the publisher or producer number The second part of the sentence is duplicated by the following paragraph: The registrant element shall be allocated by the ISBN registrant agency

16 page 16 PROPOSED CHANGE: should read: This element is the publisher or producer number. WG RESPONSE: The sentence was changed to: "This element shall be allocated by the ISBN registration agency appointed for this purpose within each registration group." and the duplicate 2 nd paragraph was deleted. COMMENT: There is a lack of consistency in the references to ISBN agencies: the specified ISBN registration agency (4.4), the ISBN registration agency designated for this purpose (4.4), registration group ISBN agencies (4.5), designated ISBN registration agency (5.1), relevant ISBN registration agency or its designated registration service (5.2), appointed ISBN registration agencies (7), etc. While we know what is meant by the designated registration service (usually the national bibliography) this term is not explained and may cause confusion. PROPOSED CHANGE: There is need for more consistency, especially with regard to designated, relevant, specified, appointed WG RESPONSE: Consistency was reviewed throughout the standard. In most cases the word "designated" was changed to "appointed" and the term "ISBN registration agency" was preferred. The terms "registration service" and "bibliographic services" in Annex E were changed to "bibliographic agency" (see Canadian comments on Annex E, below). The same change was made in clause 5.2. The second sentences of annexes B.3.4 and B.3.5 were also reworded as follows: "Tasks involving ISBN metadata may be delegated to a designated bibliographic agency acting in compliance with the specifications of this International Standard." MSZT (Hungary) 4.4 COMMENT: We recommend to change the last sentence of the first paragraph by the text as follows: Registration group ISBN agencies may choose to issue an individual PROPOSED CHANGE: "Registration group ISBN agencies may choose to issue an individual ISBN to single title producers from a common registrant element block reserved for that purpose." WG RESPONSE:. Agreed, although the phrase "single title publishers" will be used instead of "single title producers". See response to Finnish comment under clause 3, above. EDITORIAL COMMENT: There is a misprint in the third line: publisher or WG RESPONSE:. The words "or producer" have been deleted. See response to Finnish comment under clause 3, above.

17 page 17 Clause 4.5 (Publication element) DIN (Germany) COMMENT: 4.5 The publication element is allocated by the publisher This is true in many countries but not all, and for good reasons. PROPOSED CHANGE: It is proposed to add usually : The publication element is usually allocated by the publisher. WG RESPONSE: Agreed but to ensure that the word "usually" does not modify the requirement to adhere to the specifications of Annex A, the 2 nd sentence was revised to read: "The publication element shall be allocated in accordance with the specifications of Annex A and is usually allocated by the publisher of the monographic publication." MSZT (Hungary) 4.5 COMMENT: Concerning the last sentence of the first paragraph see the commend ad 4.4 WG RESPONSE: Agreed. The last sentence was revised to read: "In certain cases, ISBN agencies may choose to assign an individual ISBN to single title publishers from a common registrant element block reserved for that purpose." Clause 5 (Issuance of an ISBN) Clause 5.1 MSZT (Hungary) 5.1 COMMENT: The term ISBN prefix is not defined as such and therefore it is disturbing to speak about "An ISBN or ISBN prefix " WG RESPONSE: Wording changed to: "A registrant element shall be allocated ". Clause 5.5 SCC (Canada) We propose modifying clause 5.5 as follows (changes are shown by underlining):

18 page Different product forms (e.g. Braille, audio book, video, online electronic publication) shall be assigned separate ISBNs. Each different format of an electronic publication that is published and made separately available shall be given a separate ISBN. For example, the PDF, Microsoft Word, and HTML versions of an electronic publication shall have separate ISBNs. The underlined sentence is based on one which formerly appeared in Annex A.7.4 of the final Working Draft but disappeared when most of A.7 was replaced by a general reference to clause 5. It is a useful elaboration of the general principle and should be restored at clause 5.5. WG RESPONSE: Examples have been included in the second sentence of clause 5.5 which now reads: "Each different format of an electronic publication (e.g. ".doc", ".pdf" ".html") that is published and made separately available shall be given a separate ISBN." NSF (Norway) Clause 5.5 COMMENT: More examples on formats PROPOSED CHANGE: ( )Different formats of publications, i.e. cloth, paperback, discette, shal be given individual ISBNs. Each different format ( ) WG RESPONSE: Hardcover and paperback were added to the examples. MSZT (Hungary) 5.5 COMMENT: The enumeration should start by printed documents. The present form is misleading (i.e. it gives the impression that printed documents would be excluded) WG RESPONSE: Agreed. See above response to NSF comment. SAI (Australia) 5.5 To remove uncertainty, this section could specifically refer to the need to allocate a new ISBN when an electronic publication is reformatted (e.g. when the format in which documents were originally on a web site become obsolete, and the publisher reformats them to a current format). Addition of a final sentence: "Electronic publications should be given an individual ISBN when reformatted." WG RESPONSE: Not done. Reformatting alone does not imply publication.

19 page 19 Clause 5.6 SCC (Canada) We propose modifying clause 5.6 as follows: 5.6 A new ISBN shall be assigned if there have been significant changes to any part or parts of a publication or to its title. Small changes such as corrections of misprints shall not require new ISBN. A new ISBN shall not be assigned to a publication unchanged in edition or product form or publisher. A new ISBN shall not be assigned for changes in the price of a publication. The underlined specification formerly appeared in Annex A.7 of the final Working Draft. It disappeared when most of the section on electronic publications was replaced with a general reference to clause 5. Nevertheless it is a valid specification and should be restored as a general principle for issuance of an ISBN. WG RESPONSE: Agreed. The last sentence of 5.6 was changed to: "A separate ISBN shall not be assigned for changes in the price of a publication or for small changes such as corrections of misprints." European Booksellers Federation [via the International Booksellers Federation] Comment on point 5.6. One of the most difficult matters for booksellers are the issuing of ISBN-numbers for new editions of a book. The practices of publishers within a country varies, without even mentioning from country to country. 5.6 states that: A new ISBN shall be assigned if there have been significant changes to any part of parts of a publication or to its title. A new ISBN shall not be assigned to a publication unchanged in edition. Some examples are given but it would be good if significant changes could be specified even more. The difficulty arises especially with schoolbooks. The publisher may give a new ISBN even is there are no significant changes and it might lead to situations were a teacher may not approve that a student uses an old book even if the contents do not differ. WG RESPONSE: This will be elaborated in the Users' Manual which will explain the commercial implications of using a new ISBN in such cases. Another difficulty arises with Print On Demand: how much should a book be changed to be defined to be a new edition and when should it be given a new ISBN?

20 page 20 WG RESPONSE: For print on demand materials, changes in the product form and/or the content and/or the pagination would necessitate a new ISBN. Changes in the cover and/or insignificant changes in trim size would not. Guidelines will be provided in the Users' Manual. Clause 6 (Location and display of ISBN on electronic publications) SCC (Canada) Some useful specifications disappeared when parts of Annex A.7 (on electronic publications) in the final Working Draft were replaced or transferred to other sections of the standard. One of those was a specification concerning the display of multiple ISBNs for different formats of a publication. We propose restoring that specification somewhere in clause 6, perhaps by adding a new clause 6.4 that would apply to any type of publication (although most often to electronic publications): 6.4 Display of multiple ISBNs In cases where ISBNs for different formats of a publication appear together on a publication (as may be the case with some types of electronic publication), the individual ISBNs should be listed below each other. Each ISBN in a list of multiple ISBNs shall be qualified by information on the specific format to which it refers. WG RESPONSE: A new clause 6.4 on "Display of multiple ISBNs" was added, with some changes to the proposed wording to remove the parenthetical statement since the specification should apply to more than just electronic publications. The term "format" was also changed to "product form". It was noted that metadata should also distinguish between multiple product forms and their respective ISBNs. Clause DIN (Germany) COMMENT: The ISBN shall also be printed at the foot of the outside back cover if practicable. PROPOSED CHANGE: It is proposed to delete: if practicable ; the following sentence advises on what to do if it is not possible. WG RESPONSE: Not done. The deletion would turn this specification into a requirement which would then negate the sentence that follows.

21 page 21 Clause SAI (Australia) The instructions regarding where the ISBN should appear are sufficient for this standard. However, it might be advisable to provide further guidance on the concept of the title screen as a title page equivalent in the ISBN Users' Manual WG RESPONSE: Clause was changed to: "the page or screen that displays the title or its equivalent (e.g. the initial screen displayed when the content is first accessed and/or on the screen that carries the copyright notice)." Clause (Non-print product forms) DIN (Germany) COMMENT: Non-print product forms. The term is hardly appropriate here as electronic publications are also non-print. PROPOSED CHANGE: If the sub-heading should be kept, one would have to say something like: Physical (or, perhaps: tangible) non-print product forms WG RESPONSE: The headings for clauses and were deleted. Clause (Visual display of content stored in electronic form) DIN (Germany) COMMENT: The first paragraph largely duplicates PROPOSED CHANGE: It is suggested to merge and consolidate both paragraphs. WG RESPONSE: Done. Clause was deleted and replaced with the former 1 st paragraph of The remaining specification of clause (ISBN should be included in any metadata embedded in the publication) will need further elaboration in the Users' Manual. Clause 7 (Fees): ANSI / NISO (U.S.A.) Section 7: Suggest that this section be re-written as follows: Fees may be charged for the assignment of ISBNs by appointed ISBN registration agencies. Any such fees shall be reasonable.

22 page 22 Rationale: This restatement separates the issue of charging a fee and the requirement that fees (if charged) must be reasonable. WG RESPONSE: Agreed. The clause has been changed as proposed. Clause 8 (Administration of the ISBN system): DIN (Germany) COMMENT: The name (and address) of the International Agency are not given. PROPOSED CHANGE: This might actually go into Annex B. WG RESPONSE: Because the governance procedures and funding model for the International Agency are still under discussion, the name and address of the Registration Authority was not included in the Committee Draft. This information will be specified at a later approval stage. NOTE from SC 9 Secretariat: A description of any significant changes to the RA should accompany the draft standard when it is circulated for approval by the ISO member bodies. SCC (Canada) We note the (accidental) omission of the name and address of the Registration Authority for ISO 2108 (i.e. the International ISBN Agency) from this Committee Draft. This information must be specified in the text before it is distributed for approval as a Draft International Standard (DIS 2108). WG RESPONSE: See response to DIN comment, above. Canada also hopes to see specifications accompanying DIS 2108 that will regulate the governance of the ISBN system and ensure adequate representation from national and regional ISBN agencies in the decision-making process for issues that affect the administration, scope, resources, and integrity of the ISBN system. WG RESPONSE: Agreed. See response to DIN comment, above. Annex A (Principles for the assignment and use of ISBN) SCC (Canada) Loose-leaf publications: Annex A does not provide any explicit guidance on whether or not loose-leaf publications are eligible for ISBN. We doubt that the average user would think

23 page 23 to look for such guidance under the definitions of "continuing resource" and "ongoing integrating resource" in clause 3.3 and 3.5. A specific statement about which type of loose-leaf publication is eligible for ISBN and which is not should be added to the standard, either to the lists of inclusions and exclusions at A.1.9 and A.1.10 or as a new subclause somewhere between A.2 through A.7. For instance, the relevant indented items at A.1.9 and A.1.10 could be modified as follows. Changes are indicated by underlining: A.1.9 (list of inclusions): -- publications which are not intended by the publisher to be regularly updated or continued indefinitely; -- individual sets of looseleaf additions or replacement sheets for updating a specific edition of a publication; A.1.10 (list of exclusions): -- continuing resources including serials and ongoing integrating resources such as continually updated loose-leaf publications; For information, section 5.4 of the International ISBN Agency's Users' Manual says the following about loose-leaf publications that are eligible for ISBN. "5.4. Loose-leaf publications If a publication appears in loose-leaf form an ISBN is assigned to identify an edition at a given time. Individual issues of additions or replacement sheets will also be given an ISBN, when they are separately stocked." WG RESPONSE: No change. Looseleaf publications are covered by the existing wording at A.1.9. Specific details about eligible and ineligible types of looseleaf publications are better suited for the Users' Manual. Annex A.1.2 BSI (United Kingdom) [See U.K. comment on 3.4 (above) proposing that "different formats" should be "different product forms".] WG RESPONSE: Agreed. ANSI / NISO (U.S.A.) Editorial comment: A.1.2 "A separate ISBN..." may be "A unique ISBN.... " this change would eliminate the need for A.1.3.

24 page 24 WG RESPONSE: Not done. SFS (Finland) A.1.2 "Different formats of a publication where these are made separately available shall be assigned separate ISBNs." PROPOSED CHANGE: - the more preferable sentence would be: Versions of a publication in different product forms where these are made WG RESPONSE: No change; the existing wording is preferred. Annex A.1.3 SFS (Finland) Annex A COMMENT: As declared in the later comments concerning the chapter 3 point 3.9 the logic between terms format and product form should be clarified in points A.1.3 and A.1.7. WG RESPONSE: Done. See response to BSI comment, above. Annex A.1.5 CSNI (Czech Republic) Each following edition not only a revised one should be assigned a separate ISBN, because a following edition can be unchanged and still not a reprint. WG RESPONSE: No change. SFS (Finland) Annex A COMMENT: As declared in the later comments concerning the chapter 3 point 3.9 the logic between terms format and product form should be clarified in points A.1.3 and A.1.7. WG RESPONSE: Done. See response to BSI comment under "Scope" above.

25 page 25 Annex A.1.8 DIN (Germany) COMMENT: A new and separate ISBN should read: A separate ISBN PROPOSED CHANGE: A separate ISBN WG RESPONSE: Agreed. Annex A.1.9 (examples of material to which ISBN may be assigned) DIN (Germany) COMMENT: A.l.9: including some types of publications available through print of demand. The printing process is irrelevant for ISBN allocation; nevertheless it may be helpful for users to know that publishing on demand qualifies. PROPOSED CHANGE: Perhaps: (in their various binding or formats; also print on demand items) WG RESPONSE: The reference to print on demand publications was deleted from A.1.9. NSF (Norway) A.1.9 /A.1.10 COMMENT: What about computer games based on literature? E.g. children s literature, like Harry Potter. Should these games be included? WG RESPONSE: The words (e.g. computer games) were deleted from A MSZT (Hungary) Annex A.1.9, Examples publications which are not intended by the publisher to be regularly updated. COMMENT: This excludes monographic publications to which update pages are supplied regularly, although these are monographic publications and not serials. WG RESPONSE: See response to SCC comments regarding loose-leaf publications under Annex A., above. educational/instructional films, videos and transparencies. COMMENT: Probably these are educational (training) kits. The present description, however, is not clear because immediately the question appears: why other films, videos and transparencies are then excluded?

26 page 26 WG RESPONSE: No changes to the draft. The UNESCO Florence Agreement on the Importation of Educational, Scientific and Cultural Materials (1950) allows books and similar educational materials including educational films, videos and transparencies to be imported without customs barriers or duties in countries that are signatories. Educational films, videos, and transparencies can also be included with mixed media educational publications. SFS (Finland) A.1.9 Some examples of types PROPOSED CHANGE: -printed books and pamphlets (and their various product forms) More detailed guidance is provided in a User s Manual WG RESPONSE: A statement that "Further information is provided in the Users Manual available from the International ISBN Agency" was added at the end of A.1.9. The list of examples was rearranged according to medium and content. Annex A.1.10 (examples of material to which ISBN shall not be assigned) CSNI (Czech Republic) Even some serials can be assigned an ISBN [see above CSNI comment on 3.3] e.g. yearbooks or monographic series). WG RESPONSE: It is accepted practice for some publications to carry both an ISBN and an ISSN. The ISSN is assigned to the title of the serial as a whole; the ISBN can be assigned to individual volumes within the serial. Details will be provided in the Users' Manual. DIN (Germany) COMMENT: A.1.10 continuing resources including serials and ongoing integrating resources. This is an unnecessary tautology (see 3.3). PROPOSED CHANGE: Therefore: continuing resources or serials and onging integrating resources. WG RESPONSE: No change. The wording provides useful clarification for users. BSI (United Kingdom) 'Music sound recording' in A.1.10 should be changed to "sound recordings as abstract entities, although an ISBN may be assigned to a publication embodying a recording".

27 page 27 (NB This is to differentiate between items requiring ISRC and ISBN) WG RESPONSE: No change. Music recordings, whether abstract or not, are excluded from the ISBN. SCC (Canada) 1. Web sites: We note that Web sites were listed as exclusions in section A.1.10 of the final Working Draft (WG4 N26) but were removed from that list after the January 2003 meeting of the Working Group. There is no explanation as to why Web sites were removed from the list at A The standard should state explicitly whether or not (or which) Web sites are eligible for ISBN. If the removal of Web sites from the list of exclusions was the result of a deliberate decision that ISBN should be assigned to some types of Web sites, then the difference between a finite (i.e. monographic) type of Web site and those which are "continuing resources" needs to be made very clear in section A.7.3 of the standard. However, the Canadian ISBN Agency would prefer that Web sites are excluded from the scope of the ISBN system and suggests restoring them to the list of exclusions at A See also our comment on Annex A.7, below. WG RESPONSE: The term "Web site" is a broad term that can encompass monographic publications as well as continuing resources. For that reason, the standard will not refer specifically to "Web sites" some of which would be eligible for ISBN as monographic publications. The treatment (i.e. inclusion or exclusion) of Web-based publications will be handled in the Users' Manual. 2. Print on demand publications: We note that the list at section A.1.10 of the final Working Draft (WG4 N26) specifically excluded customized print on demand publications from being eligible for ISBN, as follows: "[Some examples of the types of material to which an ISBN shall not be issued are:] publications qualified in terms of content but available only on a limited basis, such as print on demand publications where the content is determined by the customer and not the publisher (e.g. it may comprise sections requested from several different publications), private or society publications where these are only available to members.". There is no explanation as to why this type of material was removed from the list of exclusions at A Is it intended that some of those materials should be eligible for ISBN? If so, then additional guidance must be provided on how they are handled (e.g. in terms of the ISBN registration metadata in Annex E). We suggest that these materials be restored to the list of exclusions at A Also see our comments on Annex A.6 (Print on demand publications), below. WG RESPONSE: See response to SCC comment on A.6, below. Additional guidelines for print on demand publications will be covered in the Users' Manual.

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