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I have finished reviewing the July 24 draft of the user interface guidelines. This is excellent work. However I do have a couple of comments, the first of which I'll raise in this message. Section 5.1.4 requires that if a user agent is going to render both an audio and visual logotype, that the rendering by time synchronized so they both start at the same time. Outside of accessibility contexts, this is a fine requirement. However, I'm familiar with a number of Screen Readers (software designed to make resources accessible to blind users) where this requirement would be problematic. In particular, on Windows (for products such as Window Eyes, JAWS and Microsoft's Narrator), for Unix (products such as Orca) and Mac (products such as Voice Over), rendering of the audio interface is handled by a separate software component than the visual interface. The audio interface has access to special accessibility APIs to get access to the DOM, security context and other information. So, it would be very difficult in accessibility contexts to synchronize the rendering of these two components. I suspect that if people implement this requirement they will do so by moving the audio rendering into the main browser rather than the accessibility component. That seems highly problematic, because it separates rendering of the logotype from rendering of other security context information. The information is synchronized visually, but for those who use the audio user interface, this will mean that logotypes will be rendered at some random time while the page loads, out of synchronization with any rendering of signals in section 6. As a result, it seems like techniques such as using a different voice for security context information would be ineffective at preventing spoofing of the logotype. An attacker could simply play the logotype sound at any point in order to spoof an audio user. To provide a good security experience for audio users, I think it is important that the logotype be rendered along with other audio security context information, regardless of when that happens or whether it is synchronized with visual indicators. I think the easiest fix is to remove the requirement for synchronization. If that is problematic, then scope the requirement to cases where both logotypes are rendered outside of accessibility contexts and suggest that accessibility API for browsers provide a mechanism for screen readers to suppress the browser's own rendering of the audio logotype. Screen readers are already security sensitive; allowing them to configure chrome is no worse than any other trusted component. Thanks for your Consideration, Sam Hartman Principal, Painless Security LLC