[blindLaw] Expert testimony wanted re OCR vs native-electronic PDFs

[Sai]

In my FOIA case, the government is trying to claim that converting a Word
document to a rasterized PDF (i.e. TIFF images with blackout boxes for
redaction), and then OCRing that, is just as good as the original Word
document or a native-electronic PDF export (like the result of normal "save
as PDF" or "print to PDF").

We are likely to need expert witness testimony to explain, in painstaking
detail, how an OCRed rasterization is far worse than a document that was
electronic to begin with.

This is not as only a § 504 matter, though of course accessibility is one
of the aspects of file format that should be covered (including e.g. U.S.
Access Board standards). It should also include e.g. metadata, structure,
scalability, file hashes, machine-processability, and whatever other
features are conceivably different.

Ideally this will translate into an opinion that also enumerates all the
faults, so that all off them become red flags in the future.

The judge has indicated very clearly that he intends to set precedent with
this case. In practice it will affect all of DHS (which uses the same
"FOIAXpress" software as TSA, as do a couple dozen other agencies) and
therefore the entire US federal government.

(One thing that isn't on the table, however, is "value added" electronic
metadata for accessibility, like image descriptions or Aria / functional
markup. This is only about things that were in the original internal file,
and destroyed by conversion to rasterized PDF regardless of subsequent OCR.)


If you know someone who could assist with this, or who may be interested in
filing an amicus brief, please email me directly.

I've attached the last two issued opinions in the case for reference.

Sincerely,
Sai
President, Fiat Fiendum, Inc., a 501(c)(3)

PS Non-gendered pronouns please. I'm a US citizen.

Sent from my mobile phone; please excuse the concision and autocorrect
errors.
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