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Re: [STDS-P1619] IEEE 1619 XTS submission to NIST for consideration as an Approved Mode of Operation, and Call for Sponsors

I basically agree with Jim about the extortion. However, when I asked the
NIST guys two years ago about the possible standardization of the current
P1619 encryption mode, they told me that if there would be a large number
of implementations and the algorithm proved to be sound, they would
consider recommending it.

Nobody replied to the request for a list of known implementations. Trade
secrets could be a reason, but it does not look like “a large number of
implementations” so far. Disk manufacturers certainly will not implement
XTS (several hundred million encryption devices produced a year), because
it was tailored for external (transparent) encryption modules. SW
encryption will also be better served with other encryption modes. I fear
that even if pay, NIST would reject the proposal based on the small number
of implementations.

             James Hughes <>                                               
             No Phone Info                                                 
             Available                                                  To 
             02/25/2008 10:02                                              
             PM                                                    Subject 
                                       Re: [STDS-P1619] IEEE 1619 XTS      
                                       submission to NIST for              
             Please respond to         consideration as an Approved Mode   
               James Hughes            of Operation, and Call for Sponsors 

If you are talking about asking companies for money to give IEEE to open
the document for everyone, I would support this. Baring that, IEEE will get
their money by selling individuals getting copies.

If you are talking about giving IEEE the money to allow NIST to write their
own document, then I disagree with your logic.

We (the members) are being asked by you to give up thousands each for just
one government that wants to standardize this algorithm. What are we going
to do when the UK, Canada, China, France, and the 230 other countries that
are part of the UN?

The CCM case, in addition to the fact that the 802.11 are open (for some
reason) there were clear scholarly papers on that subject out there.

Your argument about IEEE being cheap is not correct at all. This is an IEEE
group, not because it is cheap, because it is open standards committee.
T10, T11, T13 are ANSI organizations and participation does not require
membership in INCITS which is part of the SCSI Trade Association. The
others, TCG, SNIA, OASIS, as well as INCITS and the SCSI Trade Association
are neither open nor standards committees, they are trade group, industry
association or consortium. IEEE 1619 is not a trade group, industry
association or consortium and this group benefits greatly because of that
fact, and this fact has nothing to do with the cost of IEEE.

I would think that IEEE's goals would be better met by IEEE releasing the
document for the creation of any national standard provided the standard is
not modified, and the IEEE and the document information is clearly stated
in the national standard. This advertising would be valuable to IEEE. If
they do this they will make far more money than if we write our own
scholarly paper and bypass IEEE (which we can).

I am unswayed by your argument. You may suggest as you wish, but I again
strongly recommend that take my objections to IEEE.

If IEEE does not allow NIST to standardize P1619 without extorting
thousands of dollars from the members then I strongly suggest that we write
a scholarly paper that contains the algorithm and all it's tweaks using our
original stuff and submit it for publication somewhere and then give this
document to NIST.

I would expect that Jack and Curtis will be interested in this also since
this sets the precedence that any nation interested in  standardizing any
of their standards will require this payment to IEEE.

Frankly, I hope I have this wrong.


On Feb 25, 2008, at 5:36 AM, Matt Ball wrote:

      Jim and Doug,

      These are very good points, and I agree that it seems silly to donate
      our time for free, and then pay IEEE to get access to the document
      that we spent 5 hard years writing.

      But it is equally important to see the IEEE point-of-view.  IEEE has
      spent thousands of dollars over the last 5 years supporting P1619,
      through paid administrative assistants, staff liaisons, editors, and
      hasn't seen any significant return yet, nor can absolutely expect one
      (most IEEE standards are largely unused).  In this light, it seems
      very reasonable for IEEE-SA to ask for a little money to recoup its
      expenses on P1619.

      Doug, you mentioned that there was no charge for 802.11i when NIST
      wanted to make this a standard.  This perception is the result of
      some slight-of-hand by the 802 LAN/MAN standards committee.  What
      actually happens is that the 802 charges for face-to-face meetings
      and uses this money to fund free publication.  You can get 802.11i
      and most every other 802 standard for free as a result.  (See <>).  NIST's getting a
      free copy of CCM during the public review process was just a result
      of this policy.

      The reality is that IEEE-SA makes a significant amount of money off
      of 802 standards.  The 802 LAN/MAN committee can leverage some good
      rates with IEEE-SA, but they still pay.

      Asking for a thousand or so each would be a very reasonable rate for
      the service that IEEE provides.  There is no other standards group
      that I know of that could have let us develop P1619 as cheaply as
      we've done.  Most of the big groups ask for over $10k a year (TCG,
      SNIA, OASIS).  Even INCITS (T10, T11, T13) costs over a thousand a
      year now.  P1619 is still free for participation.

      Next month in Piscataway, I will show IEEE a compelling
      value-proposition for the free publication of XTS during the NIST
      public comment period (increased public-awareness of IEEE P1619,
      advertising for P1619.1, .2, .3, etc), but the chance of making this
      sale for free is low.

      Hope this clears things up!


      On Sun, Feb 24, 2008 at 1:53 PM, Doug Whiting wrote:
        I agree with Jim. I believe that NIST will just take the IEEE doc
        for information and then write their own "compatible" doc in their
        own format. So it's not really a copyright issue, as I see it. I'm
        quite sure that, when we designed and wrote up the CCM algorithm
        for 802.11i (WiFi), there was no charge when NIST wanted to make
        that a standard. Seems like there must be a way for NIST to do this
        for free.

        I spent a bunch of my time working on this effort to help out, and
        I allowed IEEE to use my example source code for free in the doc.
        Otherwise I'm not inclined to spend any more time participating in
        future IEEE standards.

        From: James Hughes
        Sent: Sunday, February 24, 2008 3:04 AMSubject: Re: [STDS-P1619]
        IEEE 1619 XTS submission to NIST for consideration as an Approved
        Mode of Operation, and Call for Sponsors

        I personally find this extortion abhorent. The use of a standard as
        a standard is what the IEEE standards orgnization is about. NIST is
        NOT going to profit from this. The only profit will be IEEE who's
        stature as a relevant standards creation organization will be
        heightened. I feel that this is being charged because the companes
        involved can afford it, not became it is right. I personally feel
        ashamed. Please, when you present your case state my opinion as an
        Sr IEEE member, conference organizer and TC Chair.

        On Feb 22, 2008, at 3:50 PM, Matt Ball wrote:

              Hi All,

              Here's the latest update on submitting XTS-AES to NIST:

              Right now Jack Cole and I are working with IEEE-SA to ask for
              a copyright release on the portion of IEEE 1619 (approved
              last December) that describes the XTS-AES cryptographic mode
              of operation.  We would like to submit XTS to NIST for
              consideration as an Approved Mode of Operation for FIPS 140-2
              certification.  Serge Plotkin has offered to write up such a

              Sun Microsystems is sponsoring me to fly out to Piscataway,
              NJ during the IEEE standards board meeting (March 26-27) to
              discuss terms for releasing the copyright during NIST' public
              review period for XTS.

              IEEE is unlikely to do this for free.  I don't know what the
              final price will be, but it will likely be in the range of
              $10k - $40k.  For this reason, I ask that all of you who
              benefit from the approval of IEEE 1619 XTS to please consider
              donating a few thousand dollars to help IEEE 1619 gain
              acceptance by NIST for FIPS 140-2.  Such acceptance would be
              highly strategic for many encryption products.

              Please let me know if your company is able to contribute to
              the copyright release of XTS.  I'll need to know before March
              26th, which gives you a month or so to check budgets.
              Contributions would be collect in April, so this will likely
              come from next quarter's budget. :)

              Please let me know if you have any questions, and I thank you
              for your support!

              Matt Ball, IEEE P1619.x SISWG Chair
              M.V. Ball Technical Consulting, Inc.
              Phone: 303-469-2469, Cell: 303-717-2717

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      Matt Ball, IEEE P1619.x SISWG Chair
      M.V. Ball Technical Consulting, Inc.
      Phone: 303-469-2469, Cell: 303-717-2717