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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 trying to deal with content/documents on one side and software on the other side in one go asks for disaster. The document "Applying WCAG 2.0 to Non-Web Information and Communications Technologies" per its draft dated July 27, 2012, claims that it can offer useful informative guidance for both [non-web] content/documents and [non-web] software at the same time / in the same document. In the last 30 years that I have been dealing with both electronic content/documents and software it never occurred to me that one could come up with any substantial statements about these two without making independent or specific statements for one or the other. Even after thinking about the concept of dealing with both in one go for quite a while it strikes me as a - please excuse my wording but this is how I see it - pretty dumb idea. If this document is ever to become meaningful and useful it should be separated into two documents, or two parts, one dealing with content/documents, the other dealing with software. Each of these two are such wide concepts already, that it will be enough of a challenge to get even one of the two right. In a nutshell: If the work is continued, split the document into two documents / parts, one for content/documents, the other for software. Olaf