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The text only indicates that use of the proper tags will constitute an accessible simple table. There is nothing addressing: 1. What headings are sufficient. 2. Where they must go. 3. What must be in them. 4. What distinguishes the table as simple. I have seen tables with an occasional blank column 1 in a body row, or with the same content repeated for several rows in column 1 where the contents of column 2, being unique, would be suitable for the row heading. Also, I have encountered misunderstanding that the heading for a row is the contents of column 1 of that row; that is, the word "heading" in English, as opposed to in the specification, is taken to only mean what the specification would consider a column heading. It would be better for the specification to be explicit. Proposed Change: Tests Procedure Add: 3. Check that row 1 column 1 is either blank or describes the contents of the entire column 1. 4. Check that row 1 subsequent columns are not blank (i.e. contain "column headings"), describe the contents of the entire column, and allow the reader to distinguish the difference in meaning between that column and immediately preceding and following columns. 5. Check that column 1 subsequent rows are not blank (i.e. contain "row headings"), describe the contents of the entire row, and allow the reader to distinguish the difference in meaning between that row and the immediately preceding rows. Expected results Add: If tests 4 and 5 cannot be met, either a complex table may be required or this table would need to be broken into multiple simple tables.