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NOTE: While my affiliations are provided for purposes of disclosure this Comment is my own and does not represent the views of those organizations. OVERVIEW The WCAG2ICT begins with an un-argued assumption: that guidelines written carefully, deliberately and specifically for web content and technologies are reasonable candidates for evaluating accessibility in “non-Web ICT”. From this dubious basis the document’s Abstract claims that it will provide information on “how” WCAG 2.0 can be applied to non-Web content. The document’s Introduction goes on to advise that the document will “…help clarify how to use WCAG 2.0”. Unfortunately, the document does not perform these self-appointed functions whatsoever. Instead, it prefers to simply claim (in most cases) that WCAG 2.0’s Success Criteria may be applied “directly as written” without any suggestion as to “how”. I’m extremely disappointed. Not only does the WCAG2ICT fail to address its own stated objectives, but reveals in stark terms that W3C has no business going “off-web” in standards development. I’ve provided details on some of my concerns below.