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The ACT format describes how to write individual rules and should not define how to deal with aspects that span multiple rules. I think this is best left to specific implementations of ACT rules, such as Auto-WCAG, that can then define how to write rules within a specific context.
Conclusion: Rules should be tied to technologies, so that they remain unambiguous. Open ended rules lead to differences of interpretation. If a technology should be added, either the rule should be updated or a new rule should be created.
We support that applicability must be described objectively, unambiguously and in plain language.
Definitions of terms that are used in more than one test rule, must be described consistently and have the same meaning wherever they are used.
Applicability must take into consideration all kinds of content on a web page and not be limited to only one specific technology, such as HTML.
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