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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"] In ISO/IEC 13066-1 (and elsewhere) there is a very relevant distinction between platform or system software and application software, e.g. as phrased in ISO/IEC 13066-1, clause 4.2.5 (which also adds a third - support software): " a) System software, which includes the operating system and other instance of platform software; b) Application software; c) Support software. " This distinction has to play a substantial role when talking about the accessibility of software. For example, on iOS, when a piece of application software is programmed strictly adhering to applicable iOS guidelines, and does not introduce any 'custom stuff', the developer often essentially does not have to do anything about accessibility, as it will be taken care of by iOS and its built-in accessibility support. In a nutshell: WCAG2ICT to distinguish between platform (or systems software) and application software, only come up with guidelines specific to each of these, and also explain how one of the two relates to the other. Also, make sure to take the whole ISO/IEC 13066-1 into account (at least where software aspects are concerned). Olaf