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The December 2011 ANPRM asserts “…it is straightforward to apply the WCAG 2.0 Success Criteria and Conformance Requirements to all electronic content.” NetCentric’s Duff Johnson, chair of the US Committee for PDF/UA, contests this claim, provides examples to show PDF/UA’s importance when considering PDF accessibility and argues for specific regulatory language that makes it clear to developers and evaluators alike that PDF accessibility must be assessed in specific technical terms.

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