UNITED STATES DISTRICT COURT
                               FOR THE DISTRICT OF COLUMBIA



 STATE OF NEW YORK, et al.,

      Plaintiffs
         v.                                                Civil Action No. 98-1233 (CKK)

 MICROSOFT CORPORATION,

      Defendant.



                                      TABLE OF CONTENTS

                                   MEMORANDUM OPINION

INTRODUCTION .............................................................1

I.        PROCEDURAL HISTORY ..............................................1

II.       LAW OF THE CASE ...................................................5

          A.        Court of Appeals Opinion ..........................................6

                    1.    Market Definition ...........................................6

                    2.    Theory of Liability ...........................................7

                    3.    Four-Part Test for Liability ...................................9

                    4.    Original Equipment Manufacturer ("OEM") Licenses ............11

                    5.    Integration of Internet Explorer ("IE") and Windows .............11

                    6.    Agreements with Internet Access Providers ("IAPs") ..............13

                    7.    Agreements with Internet Content Providers ("ICPs"), Independent
                          Software Vendors ("ISVs"), and Apple .........................13



              8.     Java .....................................................15

              9.     Intel .....................................................16

              10.    Vacating the District Court's Order of Remedy ...................18

              11.    Remand ..................................................21

        B.    District Court's Findings of Fact and Surviving Conclusions of Law .....21

        C.    General Antitrust Law of Remedies .................................25

III.    SCOPE OF THE REMEDY .............................................32

        A.    Legal Authority Related to Scope of the Remedy ......................38

        B.    Findings of Fact Related to Scope of the Remedy ......................44

              1.     Introduction ...............................................44

              2.     Treatment of Middleware ....................................47

                     a.    "Middleware" and Related Definitions in Microsoft's Proposal
                             ...................................................47

                           i.      "Non-Microsoft Middleware" in the SRPFJ .........49

                           ii.     "Non-Microsoft Middleware Product" in the SRPFJ ..51

                           iii.    "Microsoft Middleware Product" in the SRPFJ ......53

                           iv.     "Microsoft Middleware" in the SRPFJ .............54

                     b.    "Middleware" and Related Definitions in Plaintiffs' Proposal
                             ...................................................57

                           i.      "Middleware" in the SPR ........................58

                           ii.     "Microsoft Middleware Product" in the SPR ........60

              3.     New Technologies ..........................................63

                     a.    Server/Network Computing  ............................64


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             b.      Set-Top Boxes and Interactive Television Software .........68

             c.      Handheld Devices ....................................70

             d.      Web Services ........................................72

C.    Conclusions Regarding Scope of the Remedy .........................76

      1.     Server/Network Computing ..................................77

      2.     Set-Top Boxes and Interactive Television Software ...............79

      3.     Handheld Devices ..........................................81

      4.     Web Services ..............................................85

      5.     Middleware ...............................................88

D.    Alleged "Bad" Acts by Microsoft ...................................93

      1.     Findings of Fact-Allegedly New "Bad" Acts Relating to Interoperation
              .........................................................96

             a.      Kerberos ............................................96

             b.      CIFS ..............................................98

             c.      Directory Services, LDAP, ADSI ........................99

             d.      TDS ..............................................100

             e.      MAPI .............................................101

             f.      MUP ..............................................102

      2.     Old "Bad" Acts Relating to Interoperation .....................103

      3.     Conclusions Regarding "Bad" Acts Evidence ...................104

             a.      Insufficient Nexus to Java Developer Tools Deception .....104

             b.      Insufficient Nexus to First Wave Agreements .............107

             c.      Nexus to Old "Bad" Acts .............................109

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       E.    Causation Analysis ..............................................110

             1.    Microsoft's  Simple Injunction Argument ......................110

             2.    Economic Testimony .......................................113

                   a.     Dr. Shapiro's Causation Analysis ......................114

                          i.     Factual Findings ..............................114

                          ii.    Conclusions ..................................116

                   b.     Dr. Murphy's Causation Analysis ......................117

                          i.     Factual Findings ..............................117

                          ii.    Conclusions ..................................118

IV.    REMEDY-SPECIFIC CONCLUSIONS ..................................118

       A.    Original Equipment Manufacturer ("OEM") Configuration Flexibility ..119

             1.    Windows Licenses .........................................119

             2.    Installation and Display of Icons, Shortcuts, and Menu Entries ....121

             3.    Insertion of Internet Access Provider ("IAP") Registration Offers ..123

             4.    Automatic Launching of Applications .........................124

       B.    End-User Access ................................................126

       C.    Additional Protection for OEM Flexibility ..........................139

       D.    Other Participants in the Ecosystem ...............................146

             1.    Ban on Retaliation ........................................146

             2.    Agreements Limiting Support for Competing Products ...........148

             3.    Exclusive Agreements ......................................150

             4.    Agreements Regarding Placement on the Desktop ...............153


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E.    Explicitly Forward-Looking Remedies .............................154

      1.    API Disclosures (Interoperation between Windows and Microsoft
            Middleware) ..............................................155

      2.    Communications Protocols (Interoperation Between PC Operating
            Systems and Server Operating Systems) .......................156

      3.    Plaintiffs' Flawed Arguments for Overly Broad Disclosures .......158

            a.     Insufficient Connection to the Liability Findings ..........158

            b.     Harmful Effects of Cloning ...........................162

            c.     Harmful Effects of Disclosing Internal Interfaces .........164

      4.    Reasonable, Non-Discriminatory Licenses .....................165

      5.    Protection Against Hackers, Viruses, and Piracy ................167

F.    Compliance and Enforcement Provisions ...........................168

G.    Term of the Decree .............................................176

H.    Other Provisions in Plaintiffs' Proposed Remedy ....................178

      1.    Open-Source IE and Mandatory Auction of Office ..............179

      2.    Ban on Knowing Interference ...............................181

      3.    Support for Predecessor Versions ............................182

      4.    Ban on Contractual Tying  ..................................183

      5.    Ban on Retaliation for Participation in This Case ...............184

      6.    Mandatory Java Distribution ................................186

      7.    Adherence to Industry Standards .............................188

      8.    Monitoring of Microsoft's Intellectual Property Claims ...........190

      9.    Investment Reporting ......................................191


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V.      CONCLUSION ......................................................192

                                     APPENDIX  A

                                 FINDINGS OF FACT

I.      ORIGINAL EQUIPMENT MANUFACTURER ("OEM") FLEXIBILITY .....198

        A.    License Provisions ..............................................199

              1.     Plaintiffs' Third-Party Licensing Proposal .....................199

              2.     Icon Design and Placement .................................202

              3.     Automatically Launching Software ...........................204

              4.     Registration Sequences .....................................208

        B.    Remedies Related to the "Binding" of IE and Windows ...............210

              1.     "Add/Remove" Utility ......................................210

              2.     Default Settings ...........................................213

              3.     Respect for OEM Settings ...................................220

II.     UNIFORM OEM LICENSES ...........................................223

III.    PROTECTION FROM RETALIATION .................................229

        A.    Independent Software Vendors ("ISVs") and Independent Hardware
              Vendors ("IHVs") ..............................................229

        B.    Original Equipment Manufacturers ("OEMs") ......................233

IV.     TERMINATION OF AN OEM'S WINDOWS LICENSE ...................239

V.      OTHER PARTICIPANTS IN THE ECOSYSTEM .........................242

        A.    Agreements Limiting Support for Competing Products ...............242

        B.    Exclusive Agreements ...........................................247

              1.     Independent Software Vendors ("ISVs") and Original Equipment

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                    Manufacturers ("OEMs") ..................................247

             2.     Internet Access Providers ("IAPs") ...........................252

VI.    DISCLOSURE OF APIs AND COMMUNICATIONS PROTOCOLS .........254

       A.    Plaintiffs' Disclosure Proposal ....................................254

       B.    Microsoft's Disclosure Proposals ..................................267

VII. ENABLING LICENSES ...............................................271

VIII. SECURITY EXEMPTION .............................................274

IX.    TERM OF THE DECREE .............................................277

X.     OTHER PROVISIONS IN PLAINTIFFS' REMEDY PROPOSAL ...........279

       A.    Plaintiffs' Proposed Remedy ÛÛ 12, 14 ..............................280

       B.    Plaintiffs' Proposed Remedy Û 1 ...................................287

       C.    Plaintiffs' Proposed Remedy Û 5 ...................................305

       D.    Plaintiffs' Proposed Remedy Û 3 ...................................307

       E.    Plaintiffs' Proposed Remedy Û 7 ...................................310

       F.    Plaintiffs' Proposed Remedy Û 9 ...................................312

       G.    Plaintiffs' Proposed Remedy Û 13 ..................................313

       H.    Plaintiffs' Proposed Remedy Û 16 ..................................318

       I.    Plaintiffs' Proposed Remedy Û 19.f ................................322

       J.    Plaintiffs' Proposed Remedy Û 20 ..................................323



                                    APPENDIX  B

                                FINAL JUDGMENT


                                         vii



                                  MEMORANDUM OPINION 

                         "There is a remedy for all things but death . . . ."1



                                         INTRODUCTION

       Presently pending before the Court are two dueling remedy proposals seeking to redress

the wrongs inflicted upon competition by Defendant Microsoft Corporation.  These proposals

were presented to this Court following the district court's determination of liability for violation

of the Sherman Act, a partial affirmance by the United States Court of Appeals for the District of

Columbia Circuit, and an order of remand by the appellate court accompanied by instructions to

impose a remedy.  Upon review of the entire factual record in this case, the determinations of

liability affirmed by the D.C. Circuit, the parties' legal memoranda, and the relevant legal

authority, the Court enters the following legal and discretionary conclusions and order of

remedy.  The Court bases such conclusions and remedy upon its findings of fact, entered below

and in Appendix A. 

                                  I.  PROCEDURAL HISTORY

       On May 18, 1998, simultaneous with the filing of a complaint by the United States in a

related case, a group of state plaintiffs filed a civil complaint alleging antitrust violations by

Microsoft and seeking preliminary and permanent injunctions barring the company's allegedly

unlawful conduct.2  See Microsoft, 253 F.3d at 47.  In United States v. Microsoft Corp., No. 98-



       1MIGUEL DE CERVANTES,  DON  QUIXOTE, Part 2, Book 5, Chapter 10 (1615).  

       2Despite the 1998 filing of the instant suit, the antitrust issues raised in this litigation
commenced in the mid-1990s.  See United States v. Microsoft Corp., 253 F.3d 34, 49 (D.C. Cir.
2001) (en banc).

                                                   1



1232 (D.D.C.), the federal government brought claims pursuant to federal law, while in State of

New York, et al. v. Microsoft Corp., No. 98-1233 (D.D.C.), the Plaintiff States3 brought claims

pursuant to both federal and state law.  These two cases were consolidated, and following a

bench trial in the consolidated cases, Judge Thomas Penfield Jackson concluded that Microsoft

had violated ÛÛ 1 and 2 of the Sherman Act, 15 U.S.C. ÛÛ 1, 2, imposing liability for illegal

monopoly maintenance, attempted monopolization, and unlawful tying.  United States v.

Microsoft Corp., 87 F. Supp. 2d 30, 35 (D.D.C. 2000).  Correspondingly, Judge Jackson held

that Microsoft had violated the state antitrust laws analogous to ÛÛ 1 and 2 of the Sherman Act in

each of the nineteen plaintiff states and the District of Columbia.4  Id. at 54.  To remedy these

findings of liability, Judge Jackson ordered the division of Microsoft into two separate

corporations.  United States v. Microsoft Corp., 97 F. Supp. 2d 59, 64 (D.D.C. 2000).  Microsoft

filed an appeal in both cases.  On appeal, the D.C. Circuit deferred to Judge Jackson's factual

findings, Microsoft, 253 F.3d at 118, altered his findings of liability-affirming in part and

reversing in part, and vacated the remedy decree, id. at 46.

       The appellate court remanded the cases to this Court with instructions to hold a

"remedies-specific evidentiary hearing," id. at 103, and to "fashion an appropriate remedy" in



       3The "Plaintiff States" for purposes of this opinion are the States of California,
Connecticut, Florida, Iowa, Kansas, Minnesota, Utah, and West Virginia, the Commonwealth of
Massachusetts, and the District of Columbia.  Also plaintiffs in the suit, though their claims are
not addressed in this Memorandum Opinion, are the States of New York, Ohio, Illinois,
Kentucky, Louisiana, Maryland, Michigan, North Carolina, and Wisconsin.

       4This suit was originally brought by twenty states and the District of Columbia.  One
state withdrew from the action prior to the issuance of liability findings by the District Court. 
Another state settled its claims in July of 2001.  The claims of the States of New York, Ohio,
Illinois, Kentucky, Louisiana, Maryland, Michigan, North Carolina, and Wisconsin were
litigated through liability and have been conditionally settled as to the issue of remedy.  

                                                  2



light of the revised liability findings, id. at 105.  Following remand, pursuant to Court Order, the

parties in the two consolidated cases entered into intensive settlement negotiations.  See United

States v. Microsoft Corp., Nos. 98-1232 and 98-1233 (D.D.C. Sept. 28, 2001) (order requiring

the parties to enter into settlement negotiations).  The settlement negotiations did not resolve

both cases in their entirety.  However, the United States and Microsoft were able to reach a

resolution in United States v. Microsoft Corp. in the form of a proposed consent decree.  The

settlement negotiations were partially successful with regard to the states' case, State of New

York, et al. v. Microsoft Corp.; a portion of the plaintiffs in that case joined the settlement

between the United States and Microsoft.5  Consequently, those states have elected not to

proceed to a remedies-specific hearing in State of New York, et al. v. Microsoft Corp.  The states

which opted not to join the settlement between the United States and Microsoft have proposed a

remedy distinct from that presented in the proposed consent decree.

       Following expedited discovery, on March 18, 2002, an evidentiary hearing on the issue

of the remedy commenced.  The parties submitted the direct testimony in written format, while

cross-examination and re-direct testimony were offered in open court.  Over thirty-two trial days,

the Court reviewed the written direct testimony and heard the live testimony of fifteen witnesses











       5The so-called "Settling States" are the States of New York, Ohio, Illinois, Kentucky,
Louisiana, Maryland, Michigan, North Carolina, and Wisconsin.  

                                                  3



proffered by Plaintiffs6 and nineteen7 witnesses proffered by Microsoft.8  Of these witnesses,

Plaintiffs offered expert testimony from Dr. Andrew Appel, Professor of Computer Science at

Princeton University, whom the Court qualified as an expert in the field of computer science and

software engineering.  Plaintiffs' only other expert was Dr. Carl Shapiro, Professor of Business

Strategy at the University of California at Berkeley.  The Court qualified Dr. Shapiro as an

expert in the field of economics.  Microsoft presented expert testimony from Dr. John Bennett, a

professor in the Department of Computer Science and Electrical Computer Engineering at the

University of Colorado at Boulder, and Dr. Stuart Madnick, Professor of Information

Technology at the Sloan School of Management and Professor of Engineering Systems in the

Engineering Division of the Massachusetts Institute of Technology's School of Engineering. 

Both Drs. Madnick and Bennett were qualified by the Court as experts in the field of computer

science.  Microsoft also offered the expert testimony of Dr. Kenneth Elzinga, Professor of

Economics at the University of Virginia, and of Dr. Kevin Murphy, Professor of Business


       6Plaintiffs presented the testimony of thirteen fact witnesses:  (1) Peter Ashkin, (2) James
Barksdale, (3) John Borthwick, (4) Anthony Fama, (5) Richard Green, (6) Mitchell Kertzman,
(7) Dr. Carl Ledbetter, (8) Michael Mace, (9) Steven McGeady, (10) Larry Pearson, (11) David
Richards, (12) Jonathan Schwartz, and (13) Michael Tiemann; and two expert witnesses:  (1) Dr.
Carl Shapiro; and (2) Dr. Andrew Appel.

       7One of these nineteen witnesses was James Thomas ("Tom") Greene, Senior Assistant
Attorney General for the State of California, an adverse witness whose testimony Defendant
presented in the form of videotaped deposition excerpts and the transcript thereof.  Def. Ex. 1530
(Greene).  When referring to Mr. Greene's testimony, the Court cites to the page number which
appears on the deposition transcript.  

       8Defendant presented the testimony of fifteen fact witnesses:  (1) Dr. James Allchin,
(2) Linda Wolfe Averett, (3) Scott Borduin, (4) David Cole, (5) Heather Davisson, (6) Brent
Frei, (7) William H. Gates, III, (8) James Thomas ("Tom") Greene, (9) Chris Hofstader,
(10) Christopher Jones, (11) Will Poole, (12) W. J. Sanders, III, (13) Robert Short, (14) Gregg
Sutherland, and (15) Richard L. Ulmer; and four experts:  (1) Dr. John K. Bennett, (2) Dr.
Kenneth G. Elzinga, (3) Dr. Stuart E. Madnick, (4) Dr. Kevin M. Murphy.

                                                4



Economics in the Graduate School of Business at the University of Chicago.  The Court

qualified Drs. Elzinga and Murphy as experts in the field of economics.

       At the outset of this phase of the proceeding, both parties proposed to offer expert

testimony on the subject of decree enforcement from "legal experts."  In response to a request by

Microsoft to exclude such testimony, see generally "Defendant Microsoft Corporation's Motion

in Limine to Exclude the Expert Report of John H. Shenefield Which Improperly Proffers a

Legal Conclusion," the Court raised a concern that the expert legal testimony, at least as framed

by the parties, was improper.  The Court also expressed the opinion that the "expert legal

testimony" would be presented more appropriately by the attorneys in the form of oral argument. 

In response to the Court's concern, the parties voluntarily withdrew their presentation of these

expert witnesses and opted instead to present the information to the Court in the form of legal

briefs and argument.  See Trial Transcript ("Tr."). at 1633-40, 1835-40. 

                                    II.  LAW OF THE CASE

       When issues have been resolved at a prior stage in the litigation, based upon principles of

judicial economy, courts generally decline to revisit resolved issues.  More than a mere rule-of-

thumb, the "`[l]aw of the case doctrine' refers to a family of rules embodying the general concept

that a court involved in later phases of a lawsuit should not re-open questions decided (i.e.,

established as the law of the case) by that court or a higher one in earlier phases."  Crocker v.

Piedmont Aviation, Inc., 49 F.3d 735, 739 (D.C. Cir. 1995).  Similar to the law of the case

doctrine is the "mandate rule," a "`more powerful version' of the law-of-the-case doctrine, which

prevents courts from reconsidering issues that have already been decided in the same case." 

Independent Petroleum Ass'n of Am. v. Babbitt, 235 F.3d 588, 597 (D.C. Cir. 2001) (quoting


                                                 5



LaShawn A. v. Barry, 87 F.3d 1389, 1393 n.3 (D.C. Cir. 1996) ("[A]n even more powerful

version of the [law-of-the-case] doctrine--sometimes called the `mandate rule'--requires a lower

court to honor the decisions of a superior court in the same judicial system.")).  "Under the

mandate rule, `an inferior court has no power or authority to deviate from the mandate issued by

an appellate court.'"  Id. (quoting Briggs v. Pennsylvania R.R. Co., 334 U.S. 304, 306 (1948)). 

       In this case, the mandate of the appellate court requires this Court to fashion a remedy

appropriately tailored to the revised liability findings.  Microsoft, 253 F.3d at 105.  Not

surprisingly then, the starting place for this Court's determination of an appropriate remedy is

the appellate opinion in this case.  As the sole issue remaining in the case concerns a remedy for

Microsoft's violation of Û 2 of the Sherman Act, rather than a reassessment of liability, the

relevant portions of the appellate opinion consist of that court's discussion of Û 2 liability.  For

background purposes, the Court shall summarize the pertinent portions of the appellate decision,

placing the primary focus upon the appellate court's determination of Û 2 liability. 

A.     Court of Appeals Opinion

       1.      Market Definition

       The appellate court began its opinion by examining Plaintiffs'9 Û 2 Sherman Act claims

and, specifically, whether the district judge had identified the proper market for purposes of

assessing Microsoft's monopoly power.  The appellate court concluded that the district court had




       9In referring to "Plaintiffs" in this context, the Court refers to those Plaintiff States which
the Court identified in footnote 3.  The Court notes, however, that the appellate court's opinion
applies not only to the claims brought by the "Litigating States" in this case, but to the claims
brought by the so-called "Settling States" in this action and by the United States in United States
v. Microsoft, No. 98-1232 (D.D.C.). 

                                                  6



properly defined the relevant market as "the licensing of all Intel-compatible PC10 operating

systems11 worldwide."  Microsoft, 253 F.3d at 52 (quoting Microsoft, 87 F. Supp. 2d at 36). 

Having agreed with the district court's definition of the relevant market, the appellate court

adopted the district court's determination that "circumstantial evidence proves that Microsoft

possesses monopoly power."  Id. at 56.  The appellate court further noted that "if we were to

require direct proof [of monopoly power], . . . Microsoft's behavior may well be sufficient to

show the existence of monopoly power."  Id. at 57.  

       2.      Theory of Liability

       Integral to the appellate court's adoption of the market definition was its simultaneous

acceptance of Plaintiffs' theory of Microsoft's market dominance.  Both the district and appellate

courts noted that Microsoft's lawfully-acquired monopoly is naturally protected by a "structural

barrier," known as the "applications barrier to entry."  Id. at 55.  "That barrier . . . stems from

two characteristics of the software market:  (1) most consumers prefer operating systems for

which a large number of applications have already been written; and (2) most developers prefer


       10"PC" is short for "personal computer."  United States v. Microsoft, 84 F. Supp. 2d 9, Ï 1 
(D.D.C. 1999) (hereinafter cited as "Findings of Fact").

       11The appellate court, relying upon the factual testimony presented to the district court,
explained the functions of a PC operating system: 
       Operating systems perform many functions, including allocating computer memory
       and controlling peripherals such as printers and keyboards.  Operating systems also
       function as platforms for software applications.  They do this by "exposing"-i.e.,
       making available to software developers-routines or protocols that perform certain
       widely-used functions.  These are known as Application Programming Interfaces, or
       "APIs."  For example, Windows contains an API that enables users to draw a box on
       the screen.  Software developers wishing to include that function in an application
       need not duplicate it in their own code.  Instead, they can "call"-i.e., use-the
       Windows API.  Windows contains thousands of APIs, controlling everything from
       data storage to font display.  
Microsoft, 253 F.3d at 53 (citations omitted).  

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to write for operating systems that already have a substantial consumer base."  Id. (citing

Findings of Fact ÏÏ 30, 36).  This barrier creates a "chicken-and-egg" or network effects

situation, which perpetuates Microsoft's operating system dominance because "applications will

continue to be written for the already dominant Windows,12 which in turn ensures that consumers

will continue to prefer it over other operating systems."  Id.  Because "[e]very operating system

has different APIs,"13 applications written for one operating system will not function on another

operating system unless the developer undertakes the "time consuming and expensive" process

of transferring and adapting, known in the industry as "porting," the application to the alternative

operating system.  Id. at 53.  

        Plaintiffs proceeded under the theory that certain kinds of software products, termed

"middleware,"14 could reduce the "self-reinforcing cycle," Findings of Fact Ï 39, by serving as a

platform for applications, taking over some of the platform functions provided by Windows and


       12"In 1985, Microsoft began shipping a software package [for the PC] called Windows. 
The product included a graphical user interface, which enabled users to perform tasks by
selecting icons and words on the screen using a mouse."  Findings of Fact Ï 7.  In 1995,
Microsoft introduced an updated version of its Windows software known as "Windows 95." 
Id. Ï 8.  Similarly, in 1998, Microsoft released "Windows 98."  Id.  Since that time, Microsoft
has continued to update, revise, and re-create its "Windows" PC operating system.  Microsoft's
most current version of Windows is "Windows XP," which is available in both a "Home" edition
and a "Professional" edition.  

       13"APIs" are applications programming interfaces.  As Judge Jackson explained:  
       [An] operating system supports the functions of applications by exposing interfaces,
       called "application programming interfaces," or "APIs."  These are synapses at
       which the developer of an application can connect to invoke pre-fabricated blocks
       of code in the operating system.  These blocks of code in turn perform crucial tasks,
       such as displaying text on the computer screen.
Findings of Fact Ï 2.  For a supplemental definition of "API," see infra note 35.

       14Such software takes the name "middleware" because "it relies on the interfaces
provided by the underlying operating system while simultaneously exposing its own APIs to
developers" and, therefore, is said to reside in the middle.  Findings of Fact Ï 28.  

                                                  8



thereby "weaken[ing] the applications barrier to entry," id. Ï 68.  One of middleware's defining

characteristics as a software product is its ability to "expos[e] its own APIs."  Findings of Fact

Ï 28.  Eventually, reasoned Plaintiffs, if applications were written to rely on the middleware API

set, rather than the Windows API set, the applications could be made to run on alternative

operating systems simply by porting the middleware.  Ultimately, by writing to the middleware

API set, applications developers could write applications which would run on any operating

system on which the middleware was preset.  Plaintiffs focused their attention primarily upon

two such middleware threats to Microsoft's operating system dominance-Netscape Navigator15

and the Java technologies.  See Microsoft, 253 F.3d at 53.  The district and appellate courts

accepted Plaintiffs' theory of competition despite the fact that "neither Navigator, Java, nor any

other middleware product could [at that time], or would soon, expose enough APIs to serve as a

platform for popular applications."  Id.; Findings of Fact ÏÏ 28-29.  

       3.      Four-Part Test for Liability

       Having concluded that the district court properly identified the relevant market as the

market for Intel-compatible PC operating systems and properly excluded middleware products

from that market, the appellate court turned its attention to the issue of whether Microsoft

responded to the threat posed by middleware in violation of Û 2 of the Sherman Act. 

Specifically, the appellate court set out to determine whether Microsoft "maintain[ed], or

attempt[ed] to . . . maintain, a monopoly by engaging in exclusionary conduct."  Microsoft, 253

F.3d at 58.  The appellate court recounted that the district court answered that inquiry in the


       15"Although certain Web browsers provided graphical user interfaces as far back as 1993,
the first widely-popular graphical browser distributed for profit, called Navigator, was brought to
market by the Netscape Communications Corporation (`Netscape') in December 1994." 
Findings of Fact Ï 17.   

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affirmative, finding Microsoft liable for violating Û 2 of the Sherman Act:  

       by engaging in a variety of exclusionary acts . . . [s]pecifically . . . :  (1) the way in
       which it integrated [Internet Explorer] into Windows; (2) its various dealings with
       Original Equipment Manufacturers ("OEMs"), Internet Access Providers ("IAPs"),
       Internet Content Providers ("ICPs"), Independent Software Vendors (ISVs), and
       Apple Computer; (3) its efforts to contain and to subvert Java technologies; and (4)
       its course of conduct as a whole.  

Id.  In order to review the district court's findings on this point, the appellate court outlined a

four-part test for determining whether particular conduct can be said to violate antitrust law. 

"First, to be condemned as exclusionary, a monopolist's act must have an `anticompetitive

effect.' That is, it must harm the competitive process and thereby harm consumers."  Id. at 58

(emphasis in original).  Second, the plaintiff must "demonstrate that the monopolist's conduct

harmed competition, not just a competitor."  Id. at 59.  Third, "the monopolist may proffer a

`procompetitive justification' for its conduct."  Id. (quoting Eastman Kodak Co. v. Image

Technical Servs. Inc., 504 U.S. 451, 483 (1992)).  If this justification stands unrebutted by the

plaintiff, the monopolist may escape liability.  Therefore, the fourth prong of the inquiry requires

that the plaintiff "demonstrate that the anticompetitive harm of the conduct outweighs the

procompetitive benefit."  Id.  The appellate court stressed that, although evidence of intent is

relevant "to understand the likely effect of the monopolist's conduct," when assessing the

balance between the anticompetitive harm and the procompetitive effect, the trial court should

focus on the "effect of [the exclusionary] conduct, not the intent behind it."  Id. 

        Using this framework, the appellate court addressed Microsoft's challenge to each of the

findings by the district court.  The appellate court examined the district court's four basic areas

of findings with regard to Û 2 liability in an order different from that of the district court.  The

Court presents these holdings, in the order addressed by the appellate court.

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        4.      Original Equipment Manufacturer ("OEM") Licenses

        Commencing its analysis with the "[l]icenses [i]ssued to [o]riginal [e]quipment

[m]anufacturers,"16 id. at 59, the appellate court focused upon three license provisions

"prohibiting the OEMs from:  removing any desktop icons, folders, or `Start' menu entries;

(2) altering the initial boot sequence; and (3) otherwise altering the appearance of the Windows

desktop," id. at 61 (citing Findings of Fact Ï 213).  Into the category of "otherwise altering the

appearance of the Windows desktop," the appellate court subsumed the automatic launch of an

alternative user interface, the prohibition against the addition of icons and folders different in

size and shape from those used by Microsoft, and the prohibition against the use of the "Active

Desktop" feature17 to display third-party brands.  Id. at 62; see also Findings of Fact Ï 213.  Of

these license provisions, the appellate court concluded that, "with the exception of the one

restriction prohibiting automatically launched alternative interfaces, all of the OEM license

restrictions at issue represent uses of Microsoft's market power to protect its monopoly,

unredeemed by any legitimate justification."  Id. at 64.  In commencing its next area of analysis,

the appellate court noted with regard to the license restrictions imposed upon OEMs that they

"have a significant effect in closing rival browsers out of one of the two primary channels of

distribution."  Id.

        5.      Integration of Internet Explorer ("IE") and Windows

        The appellate court next turned its attention toward the "[i]ntegration of [Internet


        16Manufacturers of PCs are known as "original equipment manufacturers" or "OEMs." 
Findings of Fact Ï 10.

        17"The Active Desktop was a Microsoft feature that, if enabled, allowed the Windows
user to position Web pages as open windows that appear on the background, or `wallpaper' of
the Windows desktop."  Findings of Fact Ï 314.

                                                 11



Explorer ("IE")]18 and Windows."  Id.  At the outset of its analysis, the appellate court took a

narrow view of the district court's determination, noting that the district court's "broad[]"

condemnation of "Microsoft's decision to bind `Internet Explorer to Windows with . . . 

technological shackles'" is supported by only three specific actions taken by Microsoft. 

Id. (quoting Microsoft, 87 F. Supp. 2d at 39).  The appellate court identified these three as (1)

"excluding IE from the `Add/Remove Programs' utility"; (2) "designing Windows so as in

certain circumstances to override the user's choice of a default browser other than IE"; and (3)

"commingling code related to browsing and other code in the same files, so that any attempt to

delete the files containing IE would, at the same time, cripple the operating system."  Id. at 64-

65.  Pursuant to its four part test for liability, the appellate court concluded that Microsoft could

be held liable for the first and the third of these actions.  Id. at 65-67.  As to the second of these

actions, the override of the user's choice of default in certain circumstances, the court

determined that Microsoft had proffered a procompetitive justification that went unrebutted by

Plaintiffs, namely that the override was the result of "valid technical reasons" which justified the

override in a "few out of the nearly 30 means of accessing the Internet."  Id. at 67 (quotation

marks omitted).  Finding that Plaintiffs had neither rebutted Microsoft's procompetitive

justification, nor demonstrated that the anticompetitive effect of the challenged act outweighed

such justification, the appellate court held that "Microsoft may not be held liable for this aspect

of its product design."  Id. 






        18Internet Explorer is Microsoft's Web browser.  Findings of Fact Ï 17.  

                                                  12



       6.      Agreements with Internet Access Providers ("IAPs")

       Directing its attention to Microsoft's "agreements with various IAPs,"19 which the district

court "condemned" as exclusionary, the appellate court identified five Microsoft actions

specifically relied upon by the district court for this condemnation:  

       (1) offering IE free of charge to IAPs[;] . . . (2) offering IAPs a bounty for each
       customer the IAP signs up for service using the IE browser[;] . . . (3) developing the
       IE Access Kit ("IEAK"), a software package that allows an IAP to "create a
       distinctive identity for its service in as little as a few hours by customizing the [IE]
       title bar, icon, start and search pages," Findings of Fact Ï 249[;] . . . (4) offering the
       IEAK to IAPs free of charge, on the ground that those acts, too, helped Microsoft
       preserve its monopoly[,] [Microsoft, 87 F. Supp. 2d] at 41-42[;] . . . (5) agree[ing]
       to provide easy access to IAPs' services from the Windows desktop in return for the
       IAPs' agreement to promote IE exclusively and to keep shipments of internet access
       software using Navigator under a specific percentage, typically 25%.  See [Microsoft,
       87 F. Supp. 2d] at 42 (citing Findings of Fact ÏÏ 258, 262, 289).

Id. at 67-68.  Grouping the first four of these actions together as "Microsoft's inducements," the

appellate court held that these four actions merely "offer[ed] a consumer an attractive deal" and,

therefore, could not be treated as anticompetitive.  Id. at 68.  In contrast, the appellate court

agreed with the district court that Microsoft's exclusive contracts with IAPs "are exclusionary

devices, in violation of Û 2 of the Sherman Act."  Id. at 71. 

       7.      Agreements with Internet Content Providers ("ICPs"), Independent Software
               Vendors ("ISVs"), and Apple

       The appellate court next considered Microsoft's "dealings with ICPs, which develop

websites; ISVs, which develop software; and Apple, which is both an OEM and a software

developer."  Id. at 71.  The "deals" at issue in this portion of the case are grants of "free licenses

to bundle IE with [the ICPs' and ISVs'] offerings" and the exchange of "other valuable


       19"PCs typically connect to the Internet through the services of Internet access providers
(`IAPs'), which generally charge subscription fees to their customers in the United States." 
Findings of Fact Ï 15.   

                                                  13



inducements for [ICPs' and ISVs'] agreement to distribute, promote, and rely on IE rather than

Navigator."  Id. (quoting Microsoft, 87 F. Supp. 2d at 42-43) (brackets and quotation marks

omitted).  The district court held these agreements to be anticompetitive in violation of Û 2 of the

Sherman Act because they had the effect of "directly induc[ing] developers to focus on

[Microsoft's] own APIs rather than ones exposed by Navigator."  Id. (quoting Microsoft, 87 F.

Supp. 2d at 42-43) (quotation marks omitted).

        At the outset of its analysis in this context, the appellate court concluded bluntly that

"[w]ith respect to [Microsoft's] deals with ICPs, the District Court's findings do not support

liability."  Id.  In contrast, the appellate court sustained the district court's finding of liability

with regard to Microsoft's agreements with ISVs because Plaintiffs made "a prima facie showing

that the deals have an anticompetitive effect," and Defendant did not successfully rebut this

showing.  Id. at 72.  In particular, the appellate court found that the exclusive provisions in these

so-called "First Wave Agreements" with ISVs foreclosed a substantial share of the market for

Navigator.  Id.

        Turning its attention in this context finally to Microsoft's relationship with Apple, the

appellate court concluded that Microsoft's agreement with Apple was exclusionary in violation

of Û 2 of the Sherman Act.  Id. at 72-74.  The appellate court recounted that in mid-1997,

Microsoft and Apple entered into an agreement which obligated Microsoft to continue to release

"up-to-date" versions of its office productivity software for Apple's systems, Mac Office.  Id. at

73 (citing Findings of Fact ÏÏ 350-52).  The agreement further obligated Apple to make IE the

default browser.  Id. (citing Findings of Fact ÏÏ 350-52).  Pursuant to this same agreement,

Apple promised not to install Navigator during the "default installation," and not to "position


                                                    14



icons for non[-]Microsoft browsing software on the desktop of new Macintosh PC systems or

Mac OS upgrades."  Id. (quoting Findings of Fact ÏÏ 350-52).  Similarly, the agreement

prohibited Apple "from encouraging users to substitute another browser for IE, and state[d] that

Apple [would] `encourage its employees to use IE.'"  Id. (quoting Findings of Fact Ï 352)

(brackets omitted).  The appellate court concluded that "[t]his exclusive deal between Microsoft

and Apple ha[d] a substantial effect upon the distribution of rival browsers."  Id.  Given the

absence of a "procompetitive justification for the exclusive dealing arrangement," the appellate

court affirmed the district court's finding of Û 2 liability based upon Microsoft's exclusive deal

with Apple.  Id. at 74.  

        8.      Java

        The appellate court grouped the next category of Microsoft conduct under the heading

"Java" in reference to "a set of technologies developed by Sun Microsystems" ("Sun").  Id.  The

Java technologies are described as "another type of middleware posing a potential threat to

Windows' position as the ubiquitous platform for software development."  Id. (citing Findings of

Fact Ï 28).  The appellate opinion recounts that the district court identified four steps taken by

Microsoft to "exclude Java from developing as a viable cross-platform threat:  (a) designing a

[Java Virtual Machine ("JVM")20] incompatible with the one developed by Sun; (b) entering into

contracts, the so-called `First Wave Agreements,' requiring major ISVs to promote Microsoft's


        20"The Java technologies include:  (1) a programming language;  (2) a set of programs
written in that language, called the `Java class libraries,' which expose APIs;  (3) a compiler,
which translates code written by a developer into `bytecode';  and (4) a Java Virtual Machine
(`JVM'), which translates bytecode into instructions to the operating system. [Findings of Fact]
Ï 73.  Programs calling upon the Java APIs will run on any machine with a `Java runtime
environment,' [`JRE'] that is, Java class libraries and a JVM.  Id. ÏÏ 73, 74."  Microsoft, 253
F.3d at 74.  The terms "JRE" and "JVM" are sometimes used interchangeably to refer to the Java
platform.  The court uses the term JVM throughout this Memorandum Opinion for that purpose.

                                                 15



JVM exclusively; (c) deceiving Java developers about the Windows-specific nature of the tools

it distributed to them; and (d) coercing Intel to stop aiding Sun in improving the Java

technologies."  Id.  Of these actions, the appellate court concluded that all but the first action

were anticompetitive in violation of Û 2.  Id. at 74-78.  With regard to the first enumerated

action, the incompatible JVM, the appellate court held that because the incompatible JVM did

not have an anticompetitive effect which outweighed the procompetitive justification for the

design, it could not provide a basis for antitrust liability.  Id. at 75. 

        Specifically, with regard to the First Wave Agreements, the appellate court observed that

the district court had found the agreements, "although not literally exclusive . . . were exclusive

in practice."  Id. at 75.  Although the district court did not enter precise findings as to the effect

of the First Wave Agreements upon rival Java distribution, the appellate court determined that

"the record indicates that Microsoft's deals with the major ISVs had a significant effect upon

JVM promotion."  Id.  In the absence of procompetitive justification, the appellate court imposed

liability for this aspect of the First Wave Agreements.  Id. at 76.

        As to the Java developer tools, the appellate court's imposition of liability focused not

upon the fact that the tools created programs which were not cross-platform, but upon the fact

that Microsoft deceived software developers about the Windows-specific nature of the tools. 

Id. at 76-77.  The appellate court found that Microsoft's deception was intentional and without

procompetitive explanation.  Id. at 77.  As a result, the appellate court imposed liability for

Microsoft's deception.  Id.

        9.      Intel

        As noted above, the appellate court's final imposition of liability arose out of a "threat"


                                                    16



by Microsoft directed at Intel.  Id. at 77.  "Intel is [a firm] engaged principally in the design and

manufacture of microprocessors."  Findings of Fact Ï 95.  A segment of Intel's business

develops software, with the primary focus upon "finding useful ways to consume more

microprocessor cycles, thereby stimulating demand for advanced Intel microprocessors."  Id. 

The appellate court recounted that in 1995, Intel was in the process of "developing a high

performance, Windows-compatible JVM."  Microsoft, 253 F.3d at 77.  Furthering its efforts to

combat the cross-platform threat of Java to the Windows platform, Microsoft repeatedly "urged

Intel not to help Sun by distributing Intel's fast, Sun compliant JVM."  Id.  Eventually, Microsoft

"threatened Intel that if it did not stop aiding Sun . . . then Microsoft would refuse to distribute

Intel technologies bundled with Windows."  Id.  Intel capitulated after Microsoft threatened to

support an Intel competitor, AMD, if Intel's efforts with Java continued.  Id. 

         The appellate court acknowledged Microsoft's anticompetitive intent, as well as the

anticompetitive effect of Microsoft's actions toward Intel.  Id.  Microsoft did not offer a

procompetitive justification for its treatment of Intel, but "lamely characterize[d] its threat to

Intel as `advice.'"  Id.  Rejecting the characterization of Microsoft's threat as mere "advice," the

appellate court found the district court's imposition of liability to be supported by both fact and

law.  Id. at 77-78.  On this basis, the appellate court imposed Û 2 liability for Microsoft's threat

to Intel.  

         Corresponding to the above-described imposition of liability pursuant to Û 2 of the

Sherman Act, the appellate court imposed liability upon Microsoft for violations of the relevant

"state law counterparts of" the Sherman Act.  Id. at 46.  Beyond these findings, the appellate

court did not find Microsoft liable for any additional antitrust violations.  Specifically, the


                                                  17



appellate court reversed the district court's conclusion that Microsoft's "course of conduct" as a

whole constitutes a separate violation of Û 2.  Id. at 78.  In addition, the appellate court rejected

the district court's finding of attempted monopolization and remanded the Û 1 tying claim for

further proceedings at the district court level.21  Plaintiffs opted not to pursue the tying claim on

remand.22  Joint Status Report (Sept. 20, 2001) at 2.

           10.    Vacating the District Court's Order of Remedy

           Following its review of the district court's conclusions with regard to liability, the

appellate court considered the district court's choice of remedy.  Over the objection of Defendant

Microsoft, the district court decided to consider the merits of Plaintiffs' remedy proposal in the

absence of an evidentiary hearing.  Microsoft, 253 F.3d at 98-99; see also Microsoft, 97 F. Supp.

2d at 61.  The district court did so based on the rationale that Microsoft's evidentiary proffers

largely concerned "testimonial predictions about future events" which would be of little use to

the court in identifying an "optimum remedy."  Microsoft, 253 F.3d at 99 (quoting Microsoft, 97

F. Supp. 2d at 62).  Based upon its finding of liability for illegal monopoly maintenance,

attempted monopolization, and illegal tying, the district court entered a remedy "nearly identical

to plaintiffs' proposal" mandating the divestiture of Microsoft Corporation into an "Operating

Systems Business" and an "Applications Business."  Id. at 99-100 (quoting Microsoft, 97 F.


           21Plaintiffs' complaint also included a separate claim of "monopoly leveraging" under Û 2
of the Sherman Act.  Judge Jackson granted summary judgment in favor of Microsoft as to this
claim on the grounds that the theory runs "contrary to both economic theory and the Sherman
Act's plain language."  United States v. Microsoft, 1998 WL 614485, at *27 (D.D.C. Sept. 14,
1998). 

           22Plaintiffs' tying claim alleged that "Microsoft's contractual and technological bundling
of the IE [W]eb browser (the `tied' product) with its Windows operating system (`OS') (the
`tying' product) resulted in a tying arrangement that was per se unlawful."  Microsoft, 253 F.3d
at 84. 

                                                    18



Supp. 2d at 64).  The original decree entered by the district court, often referred to as the Initial

Final Judgment ("IFJ"), also included a number of "interim restrictions on Microsoft's conduct."

Id. at 100.  The interim restrictions included, inter alia, mandatory disclosure "to third-party

developers the APIs and other technical information necessary to ensure that software effectively

interoperates with Windows," id. (describing IFJ Û 3.b), a prohibition on Microsoft's ability to

enter into contracts which oblige third parties to limit their "`development, production,

distribution, promotion, or use of, or payment for' non-Microsoft platform-level software," id.

(quoting IFJ Û 3.e), and a "`Restriction on Binding Middleware Products to Operating System

Products' unless Microsoft also offers consumers `an otherwise identical version' of the

operating system without the middleware," id. (quoting IFJ Û 3.g). 

        The appellate court found three fundamental flaws in the district court's order of remedy,

each of which alone justified vacating the remedial decree.  The appellate court first concluded

that the failure to hold an evidentiary hearing in the face of disputed facts concerning the remedy

violated the "cardinal principle of our system of justice that factual disputes must be heard in an

open court and resolved through trial-like evidentiary proceedings."  Id. at 101.  The appellate

court rejected the district court's conclusion that evidentiary proceedings would not be useful,

noting that "a prediction about future events is not, as a prediction, any less a factual issue."  Id.

at 102.  Moreover, noted the appellate court, "drafting an antitrust decree by necessity `involves

predictions and assumption concerning future economic and business events.'"  Id. (quoting

Ford Motor Co. v. United States, 405 U.S. 562, 578 (1972)).  

        In addition to the failure to hold an evidentiary hearing, the appellate court faulted the

district court for its "fail[ure] to provide an adequate explanation for the relief it ordered."  Id. at


                                                   19



103.  Finding the trial court's devotion of "a mere four paragraphs of its order to explaining its

reasons for the remedy" insufficient, the appellate court observed that the initial remedy was not

accompanied by an explanation of the manner in which the remedy would accomplish the

objectives of a remedial decree in an antitrust case.  Id.  In this regard, the appellate court recited

that "a remedies decree in an antitrust case must seek to `unfetter a market from anticompetitive

conduct,' Ford Motor Co., 405 U.S. at 577, to `terminate the illegal monopoly, deny to the

defendant the fruits of its statutory violation, and ensure that there remain no practices likely to

result in monopolization in the future,' United States v. United Shoe Mach. Corp., 391 U.S. 244,

250 (1968)."  Id. (internal citations in original).

        Lastly, the appellate court concluded that the substantial modifications to the liability

imposed by the district court merited a new determination of the remedy for the surviving

antitrust violations.  In particular, the appellate court noted that of the three original findings of

liability, only liability for illegal monopoly maintenance in violation of Û 2 of the Sherman Act

had survived, and even this aspect of liability had been modified.  Id. at 103-04.  The appellate

court determined that where "sweeping equitable relief is employed to remedy multiple

violations, and some-indeed most-of the findings of remediable violations do not withstand

scrutiny" the remedy decree must be vacated because there no longer exists a rational connection

between the liability imposed and the remedy ascribed thereto.  Id. at 105.  Accordingly, the

appellate court remanded the case for this Court to resolve any factual disputes surrounding a

remedy and for this Court to exercise its "broad discretion" in imposing the "relief it calculates

will best remedy the conduct . . . found to be unlawful."  Id.




                                                  20



       11.     Remand

       The appellate court offered specific guidance to this Court regarding the inquiry to be

undertaken following remand.  In this regard, the appellate court focused most of its attention on

the merits of a structural remedy, noting in particular that if, in fact, Microsoft is a "unitary

company," rather than the product of mergers and acquisitions, it is not scissile.  Id.  In addition,

the appellate court reiterated its concern over the quantum of proof provided to support a causal

connection between the exclusionary conduct and Microsoft's persistence in the dominant

market position.  Id. at 107.  Notably, however, the appellate court did not remark that this Court

should consider whether or not to impose any remedy.  Instead, the appellate court advised this

Court to "consider which of the [original] decree's conduct restrictions remain viable in light of

[its] modification of the original liability decision," id. at 105, and admonished that the remedy

imposed should be carefully "tailored to fit the wrong creating the occasion for the remedy," id.

at 107 ("[W]e have drastically altered the scope of Microsoft's liability, and it is for the District

Court in the first instance to determine the propriety of a specific remedy for the limited ground

of liability we have upheld."). 

B.     District Court's Findings of Fact and Surviving Conclusions of Law

       As this Court noted above, the inquiry on remand is fundamentally constrained and

guided by the conclusions of the appellate court.  The appellate court's conclusions, in turn, rely

heavily upon the findings of fact entered by the district court following the liability trial.  After a

76-day bench trial, Microsoft, 253 F.3d at 47, Judge Jackson entered 412 numbered paragraphs

as his "Findings of Fact," see Findings of Fact, 84 F. Supp. 2d 9.  These findings provided the

factual basis for the district court's ensuing conclusions of law, issued some four months later. 


                                                  21



See Microsoft, 253 F.3d at 48.  In considering Microsoft's challenge to the district court's factual

findings, the appellate court applied the usual deference to the district court's factual conclusions

and found no "clear error," see id. at 118.  Additionally, the appellate court held that the district

court's factual findings permitted meaningful appellate review.  Id.  In particular, the appellate

court refused to reverse the district court's factual findings relevant to the "commingl[ing] of

browsing and non-browsing code."  Id. at 66.  Faced with Microsoft's continuing protestations

that the district court's commingling finding was clearly erroneous, the appellate court

specifically denied Microsoft's plea that it vacate Finding of Fact Ï 159 "as it relates to the

commingling of code."  Id. 

       Because all of the district court's factual findings survived challenge on appeal, they

comprise the law of this case and may be relied upon during the remedy phase of this

proceeding.  Crocker, 49 F.3d at 739.  Indeed, it would make little sense to proceed to craft a

remedy in the absence of substantial reliance upon the factual foundation which underlies the

liability entered in this case.  Hence, the factual findings of the district court, like the conclusions

of the appellate court, comprise the foundation upon which this court must construct a remedy. 

Still, the Court remains mindful of the vital distinction between factual findings, however

adverse, and legal conclusions. 

        A somewhat more complex problem is presented by the legal conclusions of the district

court.  Although exceedingly thorough in its analysis, the opinion of the appellate court did not

specifically address at least one of the legal conclusions reached by Judge Jackson during the

liability phase.  In Part I.A.2.a.i of its opinion, the district court addressed the manner in which

Microsoft battled the browser threat in the OEM channel of distribution.  Microsoft, 87 F. Supp.


                                                  22



2d at 39.  The district court concluded that "Microsoft's campaign proceeded on three fronts":

        First, Microsoft bound Internet Explorer to Windows with contractual and, later,
        technological shackles . . . .  Second, Microsoft imposed stringent limits on the
        freedom of OEMs to reconfigure or modify Windows 95 and Windows 98 . . . .
        Finally, Microsoft used incentives and threats to induce especially important OEMs
        to design their distributional, promotional and technical efforts to favor Internet
        Explorer to the exclusion of Navigator.

Id.  In its review of the district court's liability findings, in Part II.B.1 and 2 of its opinion, the

appellate court addressed these findings in a different sequence, considering first the license

restrictions Microsoft imposed upon the OEMs, Microsoft, 253 F.3d at 59-64, and second the

binding or "integration" of IE and Windows, id. at 64-67.  The appellate court concluded its

analysis of the OEM channel with its discussion of integration, never squarely discussing the

district court's finding with regard to the use of "incentives and threats."  See id. at 59-67.  

        Microsoft acknowledges that the appellate court declined to address individually all of

Judge Jackson's specific findings of liability.  Microsoft Proposed Conclusions of Law

(hereinafter cited as "Microsoft Prop. Concl. of Law") Ï 79.  Microsoft contends that the "acts

condemned by Judge Jackson," but not specifically addressed by the appellate court, "apparently

were the basis for his conclusion that `Microsoft's conduct as a whole . . . reinforces the

conviction that [Microsoft] was predacious.'"  Id. (quoting Microsoft, 87 F. Supp. 2d at 44)

(emphasis omitted) (alteration by Microsoft).  Drawing further upon this rationale, Microsoft

argues that the appellate court's reversal of the  "course of conduct" liability determination

implicitly reverses any of the district court's liability findings not specifically addressed by the

appellate court.  See id.

        While an attractive and simple resolution to a complex quandary, Microsoft's reasoning

is flawed.  In conflating all of Judge Jackson's remaining liability findings, Microsoft ignores the

                                                   23



express holding of the appellate court.  The appellate court determined to reverse the "course of

conduct" liability on the grounds that the district court had failed to identify the acts sufficient to

support its finding of liability:  "[T]he District Court did not point to any series of acts, each of

which harms competition only slightly but the cumulative effect of which is significant enough

to form an independent basis for liability."  Microsoft, 253 F.3d at 78 (emphasis added). 

Tellingly, the appellate court enumerated "the only specific acts" relied upon by the district court

in assessing liability on a "course of conduct" theory.  Id. (emphasis added).  In this vein, the

appellate court recounted that "the only specific acts" identified by the district court, namely

"Microsoft's expenditures in promoting its browser," were "not in themselves unlawful."  Id. 

"Because the District Court identifie[d] no other specific acts as a basis for `course of conduct

liability,'" the appellate court reversed that liability determination.  Id.

        In light of the basis for the appellate court's reversal on this point, it is antithetical to

conclude that specific anticompetitive acts clearly described by the district court elsewhere in its

conclusions of law are somehow reversed by the appellate court's rejection of the "course of

conduct" finding of liability.  Indeed, if these findings of anticompetitive conduct could have

been treated as the basis for the district court's "course of conduct" liability finding, the

appellate court would have considered such findings in reviewing the basis for the district

court's "course of conduct" liability determination.  Because the appellate court declined to look

beyond the particular acts enumerated by the district court in conjunction with its "course of

conduct" analysis, there is no basis upon which this Court can conclude that, by reversing

liability based upon a "course of conduct," the appellate court implicitly reversed findings of

anticompetitive conduct entered by Judge Jackson elsewhere in his opinion.   


                                                   24



       Although the Court rejects Microsoft's argument in this regard as without rational

support, the Court need not dwell long on the appropriate treatment of acts identified by the

district court as anticompetitive but not addressed by the appellate court, as Plaintiffs do not rely

on any of these acts.  Although Plaintiffs contend that Microsoft simply did not appeal Judge

Jackson's finding of liability based upon the "incentives and threats" described in Findings of

Fact ÏÏ 230-38, Plaintiffs assert that the clearly affirmed bases of liability are sufficient to guide

this Court's consideration of "the appropriate remedial provisions as to Microsoft's relations

with OEMs."  Plaintiffs' Proposed Conclusions of Law (hereinafter cited as "Pl. Prop. Concl. of

Law") at 5.  Plaintiffs argue that the Court may make its determination of an appropriate remedy

in the absence of any reliance upon the "incentives and threats" liability finding entered by Judge

Jackson.23  Because Plaintiffs denounce any reliance upon Judge Jackson's apportioning of

liability for coercing OEMs with incentives and threats, neither will the Court rely upon such a

finding of liability in its consideration of the appropriate remedy. 

C.     General Antitrust Law of Remedies

       It has long been established that it is the job of the district court to frame the remedy

decree in an antitrust case, and the district court has broad discretion in doing so.  Int'l Salt Co.

v. United States, 332 U.S. 392, 400-01 (1947).  "The relief in an antitrust case must be `effective

to redress the violations' and `to restore competition.'"  Ford Motor Co., 405 U.S. at 573

(quoting United States v. E. I. Du Pont De Nemours & Co., 366 U.S. 316, 326 (1961)).  Not only

should the relief ordered "cure the ill effects of the illegal conduct, and assure the public freedom


       23Beyond this single liability finding, which the Court raised with the parties, Plaintiffs
have not directed the Court to other instances where the district court ascribed liability, and the
appellate court's treatment of that finding is unclear or absent.

                                                  25



from its continuance," id. at 575 (quoting United States v. United States Gypsum Co., 340 U.S.

76, 88 (1950)), "it necessarily must `fit the exigencies of the particular case,'" id. (quoting Int'l

Salt, 332 U.S. at 401).  Ultimately, the goal of a remedy in an equitable suit is not the

"punishment of past transgression, nor is it merely to end specific illegal practices."  Int'l Salt,

332 U.S. at 401.  Rather, the remedy should "effectively pry open to competition a market that

has been closed by [a] defendant['s] illegal restraints."  Id.  Equitable relief in an antitrust case

should not "embody harsh measures when less severe ones will do," 2 PHILLIP E. AREEDA ET AL.,

ANTITRUST LAW Ï 325a, at 246 (2d ed. 2000), nor should it adopt overly regulatory requirements

which involve the judiciary in the intricacies of business management, United States v.

Paramount Pictures, 334 U.S. 131, 163 (1948). 

        In crafting a remedy specific to the violations, this Court is empowered to enjoin not only

the acts for which the defendant was found liable, but "other related unlawful acts," lest "all of

the untraveled roads to [restraint of trade] be left open and [] only the worn one be closed." 

Zenith Radio Corp. v. Hazeltine Research, Inc., 395 U.S. 100, 133 (1969) (internal quotation

marks and citations omitted).  In this regard, the Court's remedy "is not limited to prohibition of

the proven means by which the evil was accomplished, but may range broadly through practices

connected with acts actually found to be illegal."  Gypsum Co., 340 U.S. at 88-89; see also

United States v. Bausch & Lomb Optical Co., 321 U.S. 707, 724 (1944) ("Equity has power to

eradicate the evils of a condemned scheme by prohibition of the use of admittedly valid parts of

an invalid whole.").  Notwithstanding this flexibility, the Court may not simply enjoin "all future

violations of the antitrust laws."  Zenith Radio, 395 U.S. at 133.  Rather, a remedy "should be

tailored to fit the wrong creating the occasion for the remedy."  Microsoft, 253 F.3d at 107.


                                                  26



Moreover, the case law counsels that the remedial decree should be "as specific as possible, not

only in the core of its relief, but in its outward limits, so that parties may know[] their duties and

unintended contempts may not occur."  Int'l Salt, 332 U.S. at 400.

       In reversing the district court's original order of remedy in this case, the appellate court

criticized the district court for failing to explain how the remedy would "`unfetter a market from

anticompetitive conduct,' Ford Motor Co., 405 U.S. at 577 . . . `terminate the illegal monopoly,

deny to the defendant the fruits of its statutory violation, and ensure that there remain no

practices likely to result in monopolization in the future,' [United Shoe, 391 U.S. at 250]." 

Microsoft, 253 F.3d at 103.  In attempting to provide the explanation sought by the appellate

court, this Court notes at the outset that the facts and circumstances of this case necessarily affect

the extent to which this Court's order of remedy will "accomplish those objectives."  Id.  It bears

repeating that the monopoly in this case was not found to have been illegally acquired, see

United States v. Microsoft, 56 F.3d 1448, 1452 (D.C. Cir. 1995),24 but only to have been illegally

maintained.  See Microsoft, 253 F.3d at 46.  Moreover, the appellate court observed that "the

District Court expressly did not adopt the position that Microsoft would have lost its position in

the OS market but for its anticompetitive behavior."  Id. at 107 (citing Findings of Fact Ï 411). 

In this regard, the "causal connection between Microsoft's exclusionary conduct and its

continuing position in the operating systems market" was established "only through inference." 

Id. at 106-07.  Given these circumstances, as the parties concede, it does not seem to be a valid

objective for the remedy in this case to actually "terminate" Microsoft's monopoly.  Rather, the


       24In that case, which is often recognized as the precursor to this case, the appellate court
noted that "[t]he government did not allege and does not contend-and this is of crucial
significance to this case-that Microsoft obtained its alleged monopoly position in violation of
the antitrust laws."  Microsoft, 56 F.3d at 1452 (emphasis in original).  

                                                  27



proper objective of the remedy in this case is termination of the exclusionary acts and practices

related thereto which served to illegally maintain the monopoly.

       The fact that the "causal connection between Microsoft's exclusionary conduct and its

continuing position in the operating systems market" was established "only through inference,"

id., has given rise to significant disagreement between the parties as to Plaintiffs' burden on

remand.  In its appeal, Microsoft "urge[d]" the circuit court to "reverse on the monopoly

maintenance claim, because plaintiffs never established a causal link between Microsoft's

anticompetitive conduct, in particular its foreclosure of Netscape's and Java's distribution

channels."  Id. at 78.  Relying heavily on the treatise on antitrust law authored by Phillip E.

Areeda and Herbert Hovenkamp, the appellate court determined that liability in this case could

be established through an inference of causation.  Id. at 79 (citing 3 PHILLIP E. AREEDA &

HERBERT HOVENKAMP,  ANTITRUST  LAW Ï 651c, at 78 (rev. ed. 1996)).  Applying this "rather

edentulous test for causation" the appellate court identified two relevant inquiries, the

satisfaction of which would result in liability:  

       (1) whether as a general matter the exclusion of nascent threats is the type of conduct
       that is reasonably capable of contributing significantly to a defendant's continued
       monopoly power and (2) whether Java and Navigator reasonably constituted nascent
       threats at the time Microsoft engaged in the anticompetitive conduct at issue. 

Id. at 79-80.  On the record from the district court, the appellate court readily concluded that both

inquiries had been satisfied and that liability must be imposed.  Id.  

        The appellate court noted, however, that Microsoft's "concerns over causation have more

purchase in connection with the appropriate remedy."  Id. at 80.  In particular, the appellate court

noted that the strength of the causal connection is to be considered "in connection with the

appropriate remedy issue, i.e., whether the court should impose a structural remedy or merely

                                                      28



enjoin the offensive conduct at issue."  Id.  Again relying upon Areeda and Hovenkamp, the

appellate court focused on the structural remedy that had been imposed by Judge Jackson and

identified a relationship between the evidence of causation and the imposition of such a "radical"

remedy:  

       As we point out later in this opinion, divestiture is a remedy that is imposed only
       with great caution, in part because its long-term efficacy is rarely certain.  Absent
       some measure of confidence that there has been an actual loss to competition that
       needs to be restored, wisdom counsels against adopting radical structural relief.  See
       3 AREEDA & HOVENKAMP,  ANTITRUST  LAW Ï 653b, at 91-92 ("[M]ore extensive
       equitable relief, particularly remedies such as divestiture designed to eliminate the
       monopoly altogether, raise more serious questions and require a clearer indication
       of a significant causal connection between the conduct and creation or maintenance
       of the market power.").  

Id. (internal citation omitted).  Later in the opinion, the appellate court again quoted from Areeda

and Hovenkamp, highlighting the need for "a clearer indication of a significant causal

connection between the conduct and the creation or maintenance of the market power" where the

remedy is structural relief.  Id. at 106 (quoting 3 AREEDA & HOVENKAMP,  ANTITRUST  LAW

Ï 653b, at 91-92) (emphasis added by appellate court).  The appellate court instructed that in the

absence of "a sufficient causal connection between Microsoft's anticompetitive conduct and its

dominant position in the OS market . . . the antitrust defendant's unlawful behavior should be

remedied by `an injunction against the continuation of that conduct.'"  Id. (quoting 3 AREEDA &

HOVENKAMP,  ANTITRUST  LAW Ï 650a, at 67).

       In effect, the appellate court appears to have identified a proportionality between the

strength of the evidence of the causal connection and the severity of the remedy.  Accordingly,

the "[m]ere existence of an exclusionary act does not itself justify full feasible relief against the

monopolist to create maximum competition."  Id. (quoting 3 AREEDA & HOVENKAMP,


                                                  29



ANTITRUST LAW Ï 650a, at 67).  Similarly, because structural relief is "designed to eliminate the

monopoly altogether," 3 AREEDA & HOVENKAMP,  ANTITRUST  LAW Ï 653b, at 91, "wisdom

counsels against adopting radical structural relief" in the "absen[ce of] some measure of

confidence that there has been an actual loss to competition that needs to be restored," Microsoft,

253 F.3d at 80.  Instead, the court crafting a remedy must assess the strength of the causation

evidence that established liability and tailor the relief accordingly.  Id. at 107.25 

        While the appellate court's discussion of causal connection in Parts II.C and V.F of its

opinion remains instructive on the issue of remedy, it bears emphasizing that the appellate court

was largely concerned in those portions of its opinion with the propriety of a structural remedy

of dissolution.  Because Plaintiffs have not persisted in their request for a structural remedy of

dissolution, for the most part, this Court examines the existing causal connection through a

different lens than that anticipated and addressed by the appellate court.26  Nevertheless, the

Court's determination of the appropriate remedy in this case reflects, among other

considerations, the strength of the evidence linking Defendant's anticompetitive behavior to its


        25Relying upon the appellate court's discussion of causation, Microsoft has argued that
Plaintiffs have not satisfied the requirements of antitrust standing ("causation") and "antitrust
injury" and must do so in this remanded proceeding in order to obtain any remedy.  As explained
in great detail in the Court's Memorandum Opinion dated June 12, 2002, these issues were, of
necessity, addressed in conjunction with the finding and affirmance of liability by the district
court and appellate court.  See State of New York, et al. v. Microsoft Corp., No. 98-1233, slip op.
passim (D.D.C. June 12, 2002).  In setting up this straw-man argument, Microsoft ignores the
distinction between the establishment of some type of causation, which is fundamental to a
finding of liability and an assessment of the strength of the causal connection between the
anticompetitive behavior and the maintenance of the monopoly for purposes of crafting a
remedy.  Only the latter of these inquiries is presently before the Court.  

        26As the parties' arguments reflect, it is unclear whether the appellate court intended only
for this court to re-examine the existing evidence relevant to the "causal connection" in
conjunction with crafting a remedy, or whether Plaintiffs were to be given an opportunity to
supplement the evidence relating to causation. 

                                                   30



present position in the market.

        The appellate court also noted a "practical" difficulty facing this Court relevant to the

issue of remedy.  Microsoft, 253 F.3d at 48.  The appellate court appropriately observed at the

outset of its review the "problematic" fact that over six years, now seven, "have passed since

Microsoft engaged in the first conduct plaintiffs allege to be anticompetitive."  Id. at 49.  This

span of time is an "eternity in the computer industry," which is characterized by rapid change. 

Id.  The appellate court further acknowledged that the "dramatic" changes that can occur in the

computer industry in such a short period of time "threaten[] enormous practical difficulties for

courts considering the appropriate measure of relief in equitable enforcement actions."  Id.  The

appellate court recognized that in such cases "[c]onduct remedies may be unavailing . . . because

innovation to a large degree has already rendered the anticompetitive conduct obsolete (although

by no means harmless)."  Id.  At a minimum, opined the appellate court, such complexities

demand an "evidentiary hearing on remedies-to update and flesh out the available information." 

Id. 

        The parties and the Court undertook the lengthy process of precisely such an evidentiary

hearing and endeavored to update and flesh out the relevant factual information. 

Notwithstanding these substantial efforts and the benefits derived therefrom, as the appellate

court certainly anticipated, there remain difficulties inherent in crafting conduct remedies an

"eternity" after commencement of the relevant conduct.  Aware, though undeterred, by these

difficulties, the Court, in the exercise of its discretion, has arrived at an appropriate remedy for

Microsoft's illegal behavior.  Ever-mindful of the complexities identified by the appellate court

and guided by the words of the Immortal Bard that "it is excellent [t]o have a giant's strength,


                                                  31



but it is tyrannous [t]o use it like a giant,"27 the Court sets forth its findings of fact, order of

remedy, and justification therefor. 

                                  III.  SCOPE OF THE REMEDY

          On December 7, 2001, Plaintiffs and Defendant simultaneously filed their competing

proposals for a remedy in this case.  In response to Plaintiffs' proposal and the discovery which

ensued, Microsoft filed a motion in limine seeking "to exclude all evidence concerning server

operating systems, hand-held devices, television set-top boxes and Web services."  Def. Mot. in

Limine to Exclude Testimony on Products Unrelated to the Limited Ground of Liability Upheld

by the Ct. of Appeals at 1.  Microsoft argues, inter alia, that these devices and products fall

outside of the monopoly market and are unrelated to the conduct found to be anticompetitive

and, therefore, are inappropriate for consideration and coverage by the remedy in this case.  Id.

All of the Microsoft conduct which was found to be exclusionary in violation of Û 2 of the

Sherman Act was directed at "preventing the effective distribution and use of products that might

threaten that monopoly."  Microsoft, 253 F.3d at 58.  The type of products at which Microsoft

directed this conduct were identified by the district court as "middleware," with a specific focus

on the Navigator and the Java technologies.  Having reserved ruling on Microsoft's motion and

permitted the parties to further develop the relevant facts, the Court now addresses as a threshold

matter the manner in which Plaintiffs propose to treat "middleware" in the remedial phase of this

case. 

          Ordinarily, the Court might conclude rather swiftly that products which fall outside of the

relevant market are inappropriate for discussion and consideration by the Court in conjunction


          27WILLIAM SHAKESPEARE,  MEASURE FOR MEASURE, act 2, sc. 2.

                                                    32



with the crafting of a remedy for illegal monopoly maintenance.  The Court does not do so in this

case because the theory of liability pursuant to which Plaintiffs' prevailed involved Microsoft's

response to a type of product which did not fall within the monopoly market, but nevertheless

posed a potential threat to Microsoft's monopoly.  Accordingly, the Court pauses to examine the

monopoly market, the products which were excluded from that market, and the relationship of

middleware to this market. 

        The definition of the relevant product market is a necessary element of a monopolization

charge.  See United States v. Grinnell Corp., 384 U.S. 563, 570 (1966); Microsoft, 253 F.3d 51. 

As noted above, the monopoly market in this case is the market for Intel-compatible PC

operating systems.  See Microsoft, 253 F.3d at 51.  Microsoft objected to this market definition,

arguing that the district court had defined the market too narrowly, improperly excluding "three

types of products:  non-Intel compatible operating systems (primarily Apple's Macintosh

operating system, Mac OS), operating systems for non-PC devices (such as handheld computers

and portal [W]ebsites), and `middleware' products, which are not operating systems at all." 

Id. at 52.  The appellate court summarily rejected Microsoft's challenge with regard to the

exclusion of the first two types of products, observing that Microsoft had not challenged the key

district court findings of fact which determined that the products were not likely to perform the

functions of a PC anytime in the near future.  Id.  The appellate court considered more carefully

Microsoft's argument with regard to the exclusion of middleware from the market, but ultimately

concluded, id. at 54, that middleware did not meet the test of "reasonable interchangeability,"

id. at 53.

        Microsoft subsequently challenged as inconsonant the exclusion of middleware from the


                                                33



market and Plaintiffs' theory of liability that Microsoft's suppression of the middleware threat

could amount to illegal monopoly maintenance in violation of Û 2.  Id. at 54.  The appellate court

rejected this contention based upon the distinction between the level of competitive threat

relevant to establishing a market definition and the level of competitive threat relevant to the

imposition of Û 2 liability.  Id.  "Nothing in Û 2 of the Sherman Act limits its prohibition to

actions taken against threats that are already well-developed enough to serve as present

substitutes."  Id.  The appellate court observed, in this regard, that because middleware was

merely a nascent threat, id., it may simultaneously threaten to "become a viable substitute for

Windows" and yet, remain outside of the relevant monopoly market because it is "not presently a

viable substitute for Windows."  Id. (emphasis added).  Based upon this analysis, the appellate

court affirmed the district court's identification of the relevant market and determined that

Microsoft possessed monopoly power in that market.  Id. at 54-58. 

       Notably, the district court in the liability phase provided only a general definition of what

exactly constitutes "middleware," defining the term largely through example and the

identification of key attributes, rather than absolute characteristics.  As the district court pointed

out in its Findings of Fact, Navigator had "three key middleware attributes that endow[ed] it

with the potential to diminish the applications barrier to entry."  Findings of Fact Ï 69.  The

Navigator browser was a complement to Windows, rather than a substitute operating system and,

therefore, had the potential to gain widespread use.  Id.  Additionally, Navigator exposed "a set

(albeit a limited one) of APIs" which provided platform capabilities, and "it ha[d] been ported to

more than fifteen different operating systems."  Id.  Similarly, the Java technology exposed its

own APIs and, thus, enabled applications written in Java to be ported with relative ease.  Id. Ï


                                                  34



74.  Java had the potential to achieve the necessary ubiquity because it could be, and ultimately

was, distributed along with Navigator.  Id. Ï 76.  It is noteworthy that the district court regarded

the potential of Navigator and Java to "hasten the demise of the applications barrier to entry" as

a "combined effort" resulting from the "symbiosis" between the two technologies, which

exceeded the potential independently held by either of the technologies.  Id. Ï 77.  Although they

played, at best, an extremely limited role in the liability findings, mention was made of the

potential threats to Microsoft's monopoly by (1) Lotus Notes, which presented "a graphical

interface that was common across multiple operating systems; . . . exposed a set of APIs to

developers; and, like Navigator, . . . served as a distribution vehicle for Sun's Java runtime

environment," id. Ï 78; (2) Intel's Native Signal Processing software, "which interacted with the

microprocessor independently of the operating system and exposed APIs directly to developers

of media content," id.; and (3) Apple's and RealNetworks' multimedia playback technologies,

"which ran on several platforms (including the Mac OS and Windows) and similarly exposed

APIs to content developers," id. 

       Drawing from this rather amorphous definition, as noted above, Plaintiffs identify a

broad new set of technologies which they believe merits treatment by the remedy in this case. 

Plaintiffs appear to recognize that it is insufficient to simply identify other technologies that the

district court excluded from the monopoly market and argue that these technologies are relevant

to the remedy in this case on those grounds alone.28  Instead, Plaintiffs attempt to establish a

nexus between the newly identified technologies and the acts for which Microsoft was found


       28The technologies identified by Plaintiffs in this phase of the proceeding include
products which, like middleware, were excluded from the monopoly market, but which, unlike
middleware, did not play a role in the attribution of liability to Microsoft for exclusionary
conduct.  Microsoft, 253 F.3d at 52.

                                                  35



liable.  To establish this nexus, Plaintiffs propose that the newly identified technologies are

"middleware," see States' Proposed Remedy ("SPR") Û 22.w, or are software that poses a

platform threat similar to that posed by middleware.  Such a nexus, argue Plaintiffs, justifies

imposition of a remedy for Microsoft's antitrust violations that broadly addresses these newly

identified technologies, despite their virtual absence from the liability phase.  Not surprisingly,

Microsoft vehemently disagrees with the proposition that the technologies identified by Plaintiffs

are sufficiently like Navigator and Java such that these technologies should be addressed by the

Court's remedy in this case.  As a result, the Court's consideration of the relevance of these

newly identified technologies to the remedy in this case turns predominantly upon whether the

particular technology can be viewed as a kind of middleware, or at least as a "nascent" threat

which is similar to the middleware threats addressed during the liability phase.

       In the following section, the Court examines factually the various middleware and

middleware-related definitions proposed in the parties' two remedies.  To provide the necessary

background to this discussion, the Court commences the discussion with a brief examination of

the case law relied upon by Plaintiffs that is specifically relevant to the scope of the remedy. 

The Court next addresses and renders factual findings regarding the treatment of middleware

under the two competing remedy proposals, as these definitions play a significant role in

defining the scope of the remedy.  The Court then examines the new technologies identified by

Plaintiffs, as well as the theories advanced by Plaintiffs to relate these technologies to the theory

of liability in this case.  Following the entry of factual findings on these topics, the Court applies

the relevant case law and, in the exercise of its discretion, reaches appropriate conclusions

regarding the inclusion or exclusion of these technologies from the scope of the remedy.  The


                                                 36



Court's determination with regard to these technologies then informs the Court's assessment of

the appropriate treatment of middleware in the remedy.  Lastly, the Court addresses, both

factually and legally, other attempts by Plaintiffs to broaden the scope of the remedy in this case,

as well as Microsoft's opposing view, which advocates a severe narrowing of the scope of the

remedy in this case. 

       From this analysis the Court ultimately concludes that Plaintiffs' proposed definition of

"middleware" is inconsonant with the treatment of the term during the liability phase of this

case.  Plaintiffs include in their definition of "middleware" almost any software product, without

regard to the potential of the product to evolve into a true platform for other applications.  In

addition, the Court observes that Plaintiffs' middleware definition, because of its use throughout

their proposed remedy, renders various provisions of Plaintiffs' remedy ambiguous and,

therefore, unenforceable.  A further flaw in Plaintiffs' treatment of middleware is the inclusion

of technologies which fall outside of the relevant market and which do not pose a threat to

Microsoft's monopoly similar to the threat posed by nascent middleware.  While the Court does

not fault Plaintiffs' general approach in looking beyond the relevant market to search for the new

nascent threats, the Court is unable to conclude that Plaintiffs have established that all of these

technologies have the capacity to increase competition within the relevant market. 

Notwithstanding the Court's rejection of Plaintiffs' "middleware" definition, the Court

concludes that one of the technologies identified by Plaintiffs, server/network computing, has the

capacity to function in a role akin to middleware, and thereby increase competition in the

relevant market.  Accordingly, the Court determines to address this technology in a portion of

the remedy where the Court need not corrupt the definition of "middleware" in order to do so.  


                                                 37



A.     Legal Authority Related to Scope of the Remedy

       "The determination of the scope of the decree to accomplish its purpose is peculiarly the

responsibility of the trial court."  Gypsum, 340 U.S. at 89.  Plaintiffs premise their theory with

regard to the appropriate scope of the remedy for Microsoft's antitrust violations on Supreme

Court precedent that instructs that an appropriate remedy in antitrust cases typically exceeds "a

simple proscription against the precise [unlawful] conduct previously pursued," Nat'l Soc'y of

Prof'l Eng'rs v. United States, 435 U.S. 679, 698 (1978), because "a mere prohibition of the

precise scheme would be ineffectual to prevent restraints," Bausch & Lomb, 321 U.S. at 727. 

See Pl. Supp. Mem. in Opp'n to Def. Mot. in Limine to Exclude Testimony on Products

Unrelated to the Limited Ground of Liability Upheld by the Ct. at 37.  Indeed, the Supreme

Court has long held that in order to  "cure the ill effects of the illegal conduct, and assure the

public freedom from its continuance," the remedial decree imposed by the Court in this case

should "range broadly through practices connected with acts actually found to be illegal." 

Gypsum, 340 U.S. at 88-89.  Yet despite unquestionable legal authority which indicates that the

Court may address conduct beyond the precise parameters of that found to violate the antitrust

laws, Plaintiffs advocate an extraordinarily expansive view of the conduct that can be

encompassed by a remedy in this case.

       Plaintiffs rely chiefly upon four cases in which the Supreme Court sanctioned behavioral

remedies that governed conduct beyond the parameters of the antitrust violation.  The earliest of

the cases heavily relied upon by Plaintiffs is International Salt Co. v. United States, 332 U.S.

392 (1947).  In that case, the defendant, engaged in the commerce of salt and related products,

owned patents "on two machines for utilization of salt products."  Id. at 394.  The defendant


                                                  38



distributed the machines principally through leases.  Id.  The terms of the equipment leases

required the lessees to purchase from the defendant "all unpatented salt and salt tablets

consumed in the leased machine."  Id.  Discussing whether this aspect of the leases

impermissibly restrained trade, the Supreme Court concluded that although the patents conferred

upon the defendant a "right to restrain others from making, vending or using the patented

machine . . . the patents confer no right to restrain use of, or trade in, unpatented salt."  Id. at

395-96.  As a result, the defendant was held liable for the violation of antitrust law.  Id. at 396. 

To redress the liability finding, the defendant proposed a decree that enjoined it from refusing to

license, lease, or sell any machine on the grounds that a licensee, lessee, or purchaser had used or

planned to use salt not manufactured by defendant.  Id. at 399 n.8.  The government, however,

sought and obtained a decree that, inter alia, directed the defendant to lease or sell the salt

utilization machines generally to any applicant on non-discriminatory terms and conditions, id. at

398 n.7, notwithstanding the fact that the record did not reflect any "threat [by the defendant] to

discriminate after the judgment of the Court is pronounced," id. at 399.

        In response to the defendant's challenge to the decree on the grounds that "the injunction

should go no farther than the violation or threat of violation," the Supreme Court explained:  

        We cannot agree that the consequences of proved violations are so limited. The fact
        is established that the appellant already has wedged itself into this salt market by
        methods forbidden by law. The District Court is not obliged to assume, contrary to
        common experience, that a violator of the antitrust laws will relinquish the fruits of
        his violation more completely than the court requires him to do. And advantages
        already in hand may be held by methods more subtle and informed, and more
        difficult to prove, than those which, in the first place, win a market. When the
        purpose to restrain trade appears from a clear violation of law, it is not necessary that
        all of the untraveled roads to that end be left open and that only the worn one be
        closed. The usual ways to the prohibited goal may be blocked against the proven
        transgressor and the burden put upon him to bring any proper claims for relief to the
        court's attention.

                                                   39



Id. at 400.  With this statement, the Supreme Court made clear that once liable for an antitrust

violation, a defendant may be restricted in its business so as to force a relinquishment of the

fruits of the anticompetitive conduct.  It is this surrender which is to assist the courts in "pry[ing]

open to competition a market that has been closed by defendants' illegal restraints."  Id. at 401. 

Notably, however, despite the language regarding "relinquishment" of illegally obtained "fruits,"

the remedy affirmed by the Court in International Salt did not mandate a divestiture of the

defendant's assets or a structural division of the defendant, but merely regulated the terms

pursuant to which the defendant could engage in its business of leasing or selling the salt

machines.  Id. at 398 n.7. 

        The following year, in United States v. Paramount Pictures, 334 U.S. 131 (1948), the

Supreme Court reiterated its view that the equitable powers of the courts to remedy antitrust

violations may justify "uproot[ing] all parts of an illegal scheme-the valid as well as the

invalid-in order to rid the trade or commerce of all taint" of the anticompetitive actions.  Id. at

148.  The underlying facts of that case concerned, among a number of other restraints,

agreements between movie distributors and exhibitors, known as "clearances," which were

"designed to protect a particular run of a film against a subsequent run."29  Id. at 144-45.  The

district court in that case concluded that these agreements while not per se unlawful, could

constitute unreasonable restraints of trade in some instances.  Id. at 146-47.  On the facts before

it, the district court imposed liability upon the defendants for "a conspiracy to restrain trade by

imposing unreasonable clearances."  Id. at 147.  Having affirmed the finding of liability on this


       29"A clearance is the period of time, usually stipulated in license contracts, which must
elapse between runs of the same feature within a particular area or in specified theatres."  Id. at
144 n.6.

                                                  40



point, the Supreme Court examined the remedial decree provision that placed the burden on the

defendant distributor to prove the legality of any clearance that was subsequently challenged. 

The Supreme Court concluded that the remedy imposed by the district court was appropriate

because the district court "could . . . have eliminated clearances completely for a substantial

period of time, even though . . . they were not illegal per se." Id. at 148.  The Supreme Court

observed in this regard that "[t]hose who have shown such a marked proclivity for unlawful

conduct are in no position to complain that they carry the burden of showing that their future

clearances come within the law."  Id.  

       With these two rulings, the Supreme Court confirmed that a remedy in an antitrust case

seeks not only to eliminate illegal conduct, but to address the effects of that conduct upon the

marketplace.  Pursuant to this view, therefore, it may be appropriate in some instances that a

remedy address some legal conduct which, by its relation to the illegal and anticompetitive

conduct, perpetuates the antitrust violator's restraint on trade.  At the same time, however,

nothing in these two cases indicates that an antitrust violator should be subject to an outright

denial of the ability to continue to do business and to compete with other participants in the

market and in other markets.  

       Plaintiffs next direct the Court to the Supreme Court's holding in Zenith Radio Corp. v.

Hazeltine Research, Inc., 395 U.S. 100 (1969).  In that case, the Supreme Court considered

antitrust claims relating to various unlawful "patent pools," including those in Canada, England,

and Australia.  Id. at 105.  The trial court found liability relating to all of the "patent pools" and

entered "injunctive relief against further participation in any arrangement to prevent Zenith from

exporting electronic equipment into any foreign market."  Id. at 107 (emphasis added).  The


                                                  41



Supreme Court agreed with the court of appeals that there was insufficient evidence to support a

claim for money damages relating to the Australian and English markets, id. at 126-28

(England), 129 (Australia), but agreed with the district court that defendant and another entity

"were conspiring to exclude Zenith and others from the Canadian market," id. at 131. 

Accordingly, the Supreme Court concluded that, "[j]udged by the proper standard, the record

before [it] warranted the injunction with respect to Canada."  Id.  Notwithstanding this

conclusion, the Court went on to "reinstate the injunction entered by the District Court insofar as

it more broadly barred [the defendant] from conspiring with others to restrict or prevent Zenith

from entering any other foreign market."  Id. at 132.  The Court explained:  

       In exercising its equitable jurisdiction, "(a) federal court has broad power to restrain
       acts which are of the same type or class as unlawful acts which the court has found
       to have been committed or whose commission in the future unless enjoined, may
       fairly be anticipated from the defendant's conduct in the past."  . . .  We see no
       reason that the federal courts, in exercising the traditional equitable powers extended
       to them by Û 16, should not respond to the "salutary principle that when one has been
       found to have committed acts in violation of a law he may be restrained from
       committing other related unlawful acts."  

Id. at 132-33 (quoting NLRB v. Express Publishing Co., 312 U.S. 426, 435, 436 (1941)).  It is

from this passage that Plaintiffs appear to derive their familiar refrain that the remedy imposed

by this Court should reach the conduct found to violate the antitrust laws, as well as conduct

which is "the same or similar" to such illegal conduct.  Importantly, however, as the Zenith

Radio Court expressed the rule, the related acts must also be "unlawful" or of the "same type or

class" in order to warrant injunction.  Id.  In this regard, the Zenith Radio case does not support

so broad a reading as to say that clearly lawful practices may be enjoined simply because they

will weaken the antitrust violator's competitive position. 

       Finally, Plaintiffs call to this Court's attention the Supreme Court's holding in National

                                                 42



Society of Professional Engineers v. United States that an injunction that "goes beyond a simple

proscription against the precise conduct previously pursued . . . is entirely appropriate."  435

U.S. at 698.  In that case, upon finding that an association's cannon of ethics prohibiting

competitive bidding by its members was unlawful per se, the district court enjoined the

association "from adopting any official opinion, policy statement, or guideline stating or

implying that competitive bidding is unethical."  Id. at 697.  The Supreme Court affirmed

liability and rejected the defendant's contention that the provision should be struck down

because of its potential, if broadly read, to "block legitimate paths of expression on all ethical

matters relating to bidding."  Id. at 698.  Quoting from International Salt, the Supreme Court

noted that the "transgressor" could "bring any proper claims for relief [from the remedy] to the

court's attention," id. (quoting 332 U.S. at 400) (quotation marks omitted), should the defendant

"wish[] to adopt some other ethical guideline more closely confined to the legitimate objective of

preventing deceptively low bids," id. at 699 (quoting the court of appeals opinion in that case)

(quotation marks omitted).

       These four cases, argue Plaintiffs, comprise a "rich body of case law" which supports

their expansive view of the remedy.  Pl. Supp. Mem. in Opp'n to Def. Mot. in Limine to Exclude

Testimony on Products Unrelated to the Limited Ground of Liability Upheld by the Ct. of

Appeals at 40.  The Court does not agree that this body of law, though it may be "rich," can

withstand the heavy burden heaped upon it by Plaintiffs.  Undoubtedly Plaintiffs are correct that

there is ample precedent to support the imposition of conduct remedies which go beyond the

specific acts found to be anticompetitive, as the Supreme Court stated in a more recent summary

of its own body of law on the subject:  


                                                 43



        The suggestion that antitrust violators may not be required to do more than return the
        market to the status quo ante is not a correct statement of the law. In United States
        v. Paramount Pictures, Inc., 334 U.S. 131, we sustained broad injunctions regulating
        motion picture licenses and clearances which were not related to the status quo ante.

Ford Motor Co., 405 U.S. at 573 n.8 (citations and quotation marks omitted).  Plaintiffs' remedy,

however, extends this precedent well beyond its clear and logical application.  In each of the

cases relied upon by Plaintiffs, to the extent that the remedy imposed exceeded the specific

anticompetitive conduct, the restrictions were closely related to the anticompetitive conduct.  As

the Court explains in detail below, in this case, the scope of Plaintiffs' proposal exceeds most

rational extensions of injunctive relief for the anticompetitive conduct.  While some of the areas

of expansion proposed by Plaintiffs are closely related to the circumstances which gave rise to

liability in this case, the majority of practices that Plaintiffs seek to enjoin in relation to alleged

"bad" acts by Microsoft do not fall squarely within the category of "acts which are of the same

type or class" as those found to violate the antitrust laws.  Zenith Radio, 395 U.S. at 132.  

B.      Findings of Fact Related to Scope of the Remedy

        1.      Introduction

        "[A] `full exploration of facts is usually necessary in order (for the District Court)

properly to draw (an antitrust) decree' so as `to prevent future violations and eradicate existing

evils.'"  United States v. Ward Baking Co., 376 U.S. 327, 330-31 (1964) (quoting Associated

Press v. United States, 326 U.S. 1, 22 (1945)).  The Court observes at the outset of its

examination of the evidence in this case that, in the present context, the ability of the Court to

render findings of fact, in the ordinary sense, is rather limited.  As the appellate court itself

observed, "drafting an antitrust decree by necessity `involves predictions and assumptions

concerning future economic and business events.'"  Microsoft, 253 F.3d at 102 (quoting Ford

                                                   44



Motor Co., 405 U.S. at 578).  Whether or not this Court accepts a particular factual prediction

often rests upon whether the witness has identified a sound basis in fact or logic to justify the

prediction.  Where no such basis has been identified, unless self-evident to the Court, the Court

may accord little weight to the prediction.  Similarly, because of the predictive nature of the

testimony, much of the factual testimony is meaningless unless such testimony is considered

together with the accompanying argument regarding the intended use of the testimony.  The

Court observes in this regard that, quite often, Plaintiffs' arguments are presented primarily

through the testimony of their witnesses.  Recognizing the importance of addressing these

intertwined factual and legal assertions, the Court sets forth this testimony as a part of its factual

discussion.  In many instances, however, the Court neither credits nor rejects these intertwined

assertions in its factual discussion because the Court ultimately finds the argument based thereon

to be unpersuasive or irrelevant. 

       The Court further observes that, in this proceeding, factual testimony often resembles that

which would otherwise appear to be a legal or discretionary conclusion.  This convergence is

understandable given that issues of fact and law tend to lose their already faint distinctions in the

context of any discussion regarding what constitutes an appropriate or sufficient remedy. 

Nevertheless, in rendering its separate factual findings pursuant to Rule 52 of the Federal Rules

of Civil Procedure, the Court has endeavored to draw the necessary distinction between

predictive factual assertion and legal conclusion.  

       Prior to entering factual findings, the Court pauses to address the role played by

Microsoft's competitors in this proceeding.  It is both understandable and expected that Plaintiffs

would turn to industry participants to develop the factual record regarding the impact of


                                                  45



Microsoft's illegal conduct upon competition, to identify any new technologies which may be

relevant to the issue of remedy, and to explain the relation of such technologies to the monopoly

market.  Undoubtedly, testimony from industry participants played a role during the liability

phase, as such participants are most likely to have the relevant factual knowledge.  See

Microsoft, 87 F. Supp. 2d 34; Findings of Fact, 84 F. Supp. 2d 9. Thus, to the extent that

Microsoft's competitors have offered testimony explaining various technologies and the impact

of potential remedial provisions, their testimony is often useful to the Court.  Nevertheless,

where such testimony reveals a self-interest in a particular remedial provision which is not

balanced by a particular benefit to competition as a whole or to other participants in the industry,

the Court, of necessity, considers with caution the views of these industry participants.  The

Court takes careful note of those remedial proposals which advance the interests of particular

competitors and takes pains to ensure that the remedy in this case is not a vehicle by which such

competitors can advance their own interests.  See Spectrum Sports, Inc. v. McQuillan, 506 U.S.

447, 458-59 (1993); Cargill, Inc. v. Monfort of Colo., Inc., 479 U.S. 104, 110 (1986); see also

Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc., 429 U.S. 477, 488 (1977).  Any other result would

run contrary to antitrust law and principles of equity.

       The Court has considered the evidence submitted by the parties, made determinations as

to its relevancy and materiality, assessed the credibility of the testimony of the witnesses, both

written and oral, and ascertained the probative significance of the documentary and visual

evidence presented.  Based upon the Court's consideration of the entire record in this case and

all of the reasonable inferences to be drawn therefrom, the Court sets forth the following factual

findings.  The Court sets forth additional factual findings in Appendix A.


                                                 46



       2.      Treatment of Middleware

       Plaintiffs and Defendant have proposed detailed injunctive relief as the remedy in this

case.  See Pl. Ex. 1509 (hereinafter "States' Proposed Remedy" or "SPR"); Def. Ex. 1020

(hereinafter "Second Revised Proposed Final Judgment" or "SRPFJ").  Integral to understanding

the two remedies proposed in this case is a preliminary understanding of the manner in which the

two remedies treat middleware.  In simple terms, the treatment of middleware in the two

remedies plays a significant role in defining the scope of products which will receive various

protections under the terms of the respective remedies.  For example, both proposed remedies

impose restrictions upon Microsoft's ability to retaliate against companies which sell or support

third-party middleware.  See, e.g., SPR Û 8; SRPFJ Û III.A.  In addition, both proposed remedies

address the middleware portions of Microsoft's operating system, imposing certain requirements

upon Microsoft with regard to its product design related to these portions of its operating system. 

See, e.g., SPR Û 2.c; SRPFJ Û III.H.  By way of further example, both proposed remedies require

Microsoft to provide certain kinds of technical information with regard to the interaction

between its operating system and its software products which are treated as Microsoft

middleware.  See, e.g., SPR Û 4; SRPFJ Û III.D.  By addressing middleware of various types,

both remedies intend to increase the ability of third-party middleware to provide platform

capabilities which rival the platform function of the Windows operating system.

       a.      "Middleware" and Related Definitions in Microsoft's Proposal

       Despite these similarities in addressing the treatment of middleware, the two remedy

proposals adopt rather distinct and divergent approaches to defining the term.  Microsoft's

proposed remedy does not actually use the term "middleware" standing alone, but instead


                                                47



addresses primarily two types of software:  "Microsoft Middleware Products" and "Non-

Microsoft Middleware Products."  As is quite apparent from the terminology, Microsoft's

remedy proposal draws a distinction between middleware technology incorporated into

Microsoft's own products and the middleware capabilities of third-party software products. 

Somewhat counter-intuitively, "Microsoft Middleware Products" and "Non-Microsoft

Middleware Products," as defined in the SRPFJ, do not mirror each other, meaning that

"Microsoft Middleware Products" are not defined as the Microsoft versions of "Non-Microsoft

Middleware Products."  See SRPFJ Û VI.K, N.  This unexpected relationship between the two

definitions results from the different uses of the definitions in specific portions of Microsoft's

remedy proposal. 

       The term "middleware," as used in the liability phase of this case, was not limited to

precise types of functionality, but instead encompassed products displaying certain "key"

attributes that "endow" the technology with the "potential to diminish the applications barrier to

entry."  Findings of Fact Ï 69.  In other words, the middleware in need of protection was

characterized as the software products which "Microsoft feared . . . because they facilitated the

development of user-oriented software that would be indifferent to the identity of the underlying

operating system."  Findings of Fact Ï 78.  The liability findings of this case primarily concern

Microsoft's efforts to compete with two specific middleware products:  (1) the Navigator Web

browsing software from Netscape and (2) Sun's Java technologies.  See Microsoft, 253 F.3d at

53.  Plaintiffs established that Navigator and Java, because they were cross-platform-meaning

they ran on multiple PC operating systems-had the potential to develop into software

development platforms that would attract the attention of applications developers.  See id.  The


                                                 48



district and appellate courts accepted Plaintiffs' theory that, if a sufficient number of ISVs wrote

applications that drew on capabilities provided by these middleware platforms, consumers would

have less interest in running applications on Windows and might use non-Microsoft operating

systems under their Web-browsing and/or Java software layer, such that the Windows base could

be replaced with some other operating system that would support the middleware.  Id. at 55;

Findings of Fact ÏÏ 28-29.  In this regard, the surviving liability determinations turn largely on

Microsoft's efforts to thwart Netscape's ability to distribute Navigator and Sun's ability to

distribute Java in the primary channels of distribution.  See Microsoft, 253 F.3d 59-78.

       The potential competitive significance of Navigator and Java turned on the key attributes

of those programs which, together, held the potential to provide an easily portable software

development platform.30  Findings of Fact ÏÏ 69-77.  First, the software provided a complement

to Windows, rather than a replacement.  Id. ÏÏ 69-70, 73-74.  In addition, Navigator and Java

exposed a set of APIs which provided a platform so that developers, relying on the platform

capabilities of the programs, could write multiple types of applications to run on Navigator and

Java.  Id. Ï 69, 74.  Finally, Navigator and Java both ran on Windows, as well as other PC

operating systems, such that reliance on Navigator and Java's API set would render applications

instantly portable to multiple operating systems.  Id.  Adding to this potential was the newly

emerging popularity of the Internet and Internet browsing software, which provided a significant

purchasing incentive to first-time PC buyers.  Id. Ï 70.

       i.      "Non-Microsoft Middleware" in the SRPFJ

       Given the defining trait of running on multiple operating systems, "middleware," as the


       30A "platform" is software that provides functionality upon which ISVs can call during
the creation of their own software programs.  See Gates Ï 52.

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term was utilized during the liability phase, most frequently refers to third-party, non-Microsoft

software.  Microsoft's own software products are unlikely to behave as true middleware because

Microsoft, as the monopolist, has little interest in creating an alternative platform which is

portable from Microsoft's operating system to a non-Microsoft operating system.  Still, because

Microsoft software products often provide a functionality similar to that provided by a third-

party middleware product, such software is often treated as Microsoft middleware.  Microsoft's

remedy proposal therefore uses the term "Non-Microsoft Middleware" to make clear the

reference to third-party software.  "Non-Microsoft Middleware" is defined in the SRPFJ as:

       a non-Microsoft software product running on a Windows Operating System Product
       that exposes a range of functionality to ISVs through published APIs, and that could,
       if ported to or made interoperable with, a non-Microsoft Operating System, thereby
       make it easier for applications that rely in whole or in part on the functionality
       supplied by that software product to be ported to or run on that non-Microsoft
       Operating System.

SRPFJ Û VI.M.  "Non-Microsoft Middleware," as that term is defined in the SRPFJ, captures the

essence of the middleware threats which were discussed during the liability phase.  See id.  In

fact, the definition of "Non-Microsoft Middleware" expands beyond the middleware discussed at

the liability phase in that it does not require that the software products already run on multiple

PC operating systems, only that they have the potential, if ported to such operating systems, to

serve as platforms for applications.  See id.  

       The term "Non-Microsoft Middleware" is noteworthy for the breadth of its coverage of

software products without limitation as to specific types of functionality.  Consistent with the

liability phase, these software products are principally limited by the requirement that they run

on Microsoft's monopoly product-Windows, while exposing a range of functionality through

published APIs.  Id.  "Non-Microsoft Middleware" is utilized in significant portions of

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Microsoft's remedy proposal and is the term which most often identifies the products which will

receive some form of protection under Microsoft's remedy proposal.  For example, Û III.A of the

SRPFJ prohibits Microsoft, inter alia, from retaliating against OEMs for supporting in any way

"Non-Microsoft Middleware."  Id. Û III.A.  Likewise, Û III.C of Microsoft's remedy proposal

restricts Microsoft's ability to impose license restrictions upon OEMs with regard to the

installation and display of icons, shortcuts, and menu entries for "Non-Microsoft Middleware." 

Id. Û III.C.  Therefore, under the umbrella of "Non-Microsoft Middleware," Microsoft's remedy

proposal affords coverage or protection to a wide variety of third-party software products.31 

       ii.     "Non-Microsoft Middleware Product" in the SRPFJ

       Microsoft's proposed remedy also uses the term "Non-Microsoft Middleware Product,"

which is defined similarly to "Non-Microsoft Middleware," but adds a requirement that "at least

one million copies" of the product "were distributed in the United States within the previous

year."  SRPFJ Û VI.N.  Some of Plaintiffs' witnesses contended that the definition of "Non-

Microsoft Middleware Product" is in discord with the use of the term "middleware" during the

liability phase because it requires some degree of popularity for the product before it is covered

by the definition as a middleware product.  Specifically, Plaintiffs' witnesses pointed to the

"one-million-copies" threshold mark in the "Non-Microsoft Middleware Product" definition and

argued that it excludes the kinds of nascent threats which are most similar to the products toward

which Microsoft was found to have directed its illegal conduct.  See, e.g., Ashkin Ï 169;

Richards Ï 139.  To the contrary, the one-million-copies threshold is consistent with the


       31For example, pursuant to the definition of "Non-Microsoft Middleware," products
competitive with Microsoft Office would receive protection from various types of adverse action
by Microsoft, notwithstanding the fact that Microsoft Office is a product which has always been
separate and distinct from Microsoft's operating system. 

                                                51



treatment of middleware in the liability phase of this proceeding.  The one-million-copies

distribution requirement in the definition of "Non-Microsoft Middleware Products" is reflective

of the treatment of middleware threats in this case because the district and appellate courts did

not merely focus on any software with the potential to serve as a multi-purpose platform, but

specifically focused upon middleware which could "gain widespread use based on its value as a

complement to Windows."  Findings of Fact Ï 69; see also id. ÏÏ 72 (describing Navigator's

widespread adoption after its release), 76 (describing Java's inclusion in Navigator).  The

products upon which Judge Jackson focused in imposing liability were not merely middleware,

but were middleware threats, because of their popular use, platform capabilities, and their

ensuing ability to reduce the applications barrier to entry.  Findings of Fact ÏÏ 69-78. 

       Additionally, it is noteworthy that the term "Non-Microsoft Middleware Product" is

utilized in only one section of Microsoft's proposed remedy, Û III.H.  This portion of Microsoft's

remedy proposal requires Microsoft to configure its operating system products so as to permit

the removal of end-user access to, and certain "automatic invocations"32 of "Microsoft

Middleware Products," as well as "Non-Microsoft Middleware Products."  SRPFJ Û III.H.1. 

This portion of the SRPFJ also provides for the replacement of "Microsoft Middleware

Products" with "Non-Microsoft Middleware Products" in very specific instances.  Id. Û III.H.2. 

Because this portion of Microsoft's proposed remedy requires Microsoft to undertake the

redesign of its own product, Jones Ï 119, the one-million-copies threshold relieves Microsoft of

the obligation to redesign its product to accommodate a particular piece of software with

extremely limited use.  Elsewhere in Microsoft's remedy proposal, where there is no burden


       32The term "automatic invocations" refers generally to the launching of a particular piece
of software functionality without the direct invocation of such software by the user. 

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upon Microsoft to redesign its product, the one-million-copies distribution threshold does not

apply.  See, e.g., SRPFJ Û III.A, C.

       To emphasize the limited relevance of the one-million-copies threshold, the Court

reiterates that Microsoft's remedy proposal primarily utilizes the term "Non-Microsoft

Middleware," which does not incorporate any minimum threshold for distribution, in its

extension of protection to products well beyond the types of products that were addressed during

the liability phase.  This lack of a threshold leads to the inclusion in the remedy of virtually any

nascent "middleware" technology, regardless of its popularity or promise of success.  Therefore,

the key distinction between the two definitions is rooted in the liability determination, as well as

practical considerations attendant to the imposition of design obligations upon Microsoft.

       iii.    "Microsoft Middleware Product" in the SRPFJ

       In contrast to the broad definitions of "Non-Microsoft Middleware" and "Non-Microsoft

Middleware Products," the term "Microsoft Middleware Product" is defined according to a

specific set of existing Microsoft functionalities, as well as future Microsoft functionality.  The

existing set of functionalities which are included in "Microsoft Middleware Product" are those

provided by Internet Explorer, Microsoft's Java Virtual Machine, Windows Media Player,

Windows Messenger, Outlook Express, and their successors in Windows.  SRPFJ Û VI.K.1.  The

future technologies captured by the definition of "Microsoft Middleware Product" encompass

software included in Windows that provides the functionality of Internet browsers, email client

software, networked audio/video client software, and instant messaging software.  Id. Û VI.K.2.

Other future technologies captured in the definition of "Microsoft Middleware Product" are

those functionalities which are both distributed as part of Windows and distributed separately


                                                 53



from Windows by Microsoft, trademarked by Microsoft, and which compete with third-party

middleware products.  Id.  

       "Microsoft Middleware Product" extends well beyond the Microsoft counterparts to the

two non-Microsoft technologies which were primarily at issue in the liability phase of this case

(Java and Navigator) to include media playback technology, which was addressed briefly during

the liability phase, Findings of Fact Ï 78, and to govern the Microsoft counterparts to other well-

recognized potential middleware threats to Windows' dominance, such as email client software

and instant messaging software.  See SRPFJ Û VI.K.  The term "Microsoft Middleware Product,"

as defined in the SRPFJ, focuses upon software technologies which have been incorporated or

"integrated" into the Windows operating system, in reflection of the fact that the two

technologies principally at issue during the liability phase were mirrored by Microsoft

technologies that had been incorporated into Windows.  See Findings of Fact ÏÏ 133, 155, 397-

98.  The focus on technologies incorporated into Windows further reflects the fact that Microsoft

software technologies that have never been part of Windows fall outside of Microsoft's

monopoly product, which, of course, is the focus of this proceeding.  

       iv.     "Microsoft Middleware" in the SRPFJ

       In portions of Microsoft's proposed remedy, there is a need to identify the specific code

in Windows.  Hence, Microsoft's remedy proposal uses the term "Microsoft Middleware," which

is largely reflective of the definition of "Microsoft Middleware Product," but which is further

limited to the code separately distributed and trademarked or marketed as a major version of the

Microsoft Middleware Product.  SRPFJ Û VI.J.  The term "Microsoft