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[This email has been submitted as a comment on the July 27, 2012 draft of "Applying WCAG 2.0 to Non-Web Information and Communications Technologies"] From my point of view WCAG2 is a solution looking for a additional problems to solve. Invented with web content in mind, at least some would claim.agree that it became quite successful - at least for web content. Now, being encouraged by that success it seems WCAG2 proponents felt like they should find other stuff to which WCAG2 concepts could be applied. A little bit like trying to figure out what a hammer - quite good at dealing with nails - could do with screws. While some functionality could be achieved, hammers and screws will never be a good match. Instead, in order to deal with screws, one would have to start thinking starting form what screws are, not even thinking of a hammer. A concept essential to screws - 'turning' - does not even exist in the world of hammers and nails. Along the same lines I think in order to come up with something useful and meaningful for non-web content.documents, one would have to start from non-web content/documents, not from a tool that has been proven to work well with web content/documents. Otherwise there is a drastic risk to miss essential aspects, and it could easily happen that WCAG2 concepts cover non-web content/documents quite well where actually they don't (or it is at least unknown / undefined to which degree they cover them). And thus the quality and value of "applying WCAG2 to non-web ICT" is undefined / unknown. Maybe the WAI is not even the ideal context to start doing something about non-web content/documents...? Olaf