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`and on my conversamns with computer managers in large organizations, deposition
`testim:my, and docUIIXmts in connection with tlmi case. The major points cliicussed in
`tlmi testirmny are as fullows:
`• It is difficult to define software products according to any specific grouping of
`files. Software products are typically defined according to their features.
`
`• Organizations generally have different needs for brow;er products, which they
`view as applications, and operating system products.
`
`• Whereas all organizations using computers need operating systems, some
`wish
`to have no brow;ers deployed to some or all users.
`
`• Many organizations wish to use brow; er products and have compelling
`reasons
`to standardize on a single such product, but want to select that product
`independently of any particular operating system.
`
`• Many organizations, having standardized on Wmdow; 95 for a large portion of
`their operating system needs, have sought, at some cost, to remove Internet
`Explorer from their PCs by either deleting the means of access to Intern.et
`Explorer or standardizing on the original version of Wmdow; 95, which did
`not come with Internet Explorer at all.
`
`• Some organizations, having moved to Wmdow; 98 or considering doing so, are
`confronted with the inability to remove Internet Explorer from the operating
`system, and accordingly view themselves as having little or no choice but to
`standardize on Internet Explorer.
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`II. BACKGROUND AND QUALIFICATIONS
`
`2. I am a seminar developer, seminar instructor, author of computer books and
`videos, and computer consultant. My computer knowledge is a cornbinamn of
`education,
`years of hands-on experience, and thousands of discussions in furmal and infunml
`settings with other computer users. I am President of Independent Software, Inc., in
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`Golden, Colorado, a company I co-fuunded in 1982.
`3. Over the years, my consuhing activities have covered a wide range of
`computing topics, including hardware platfurms and software enviromnmts. My early
`consuhing practice fucused on custom programming and system integration Later, I
`fucused on teclmical support and microcomputer networking in organimtions of all si7.es.
`Recently, writing and teaching have occupied tmre of my titre than consulting. I have
`submitted my curriculum vitae to the Court as Governmmt Exhibit 1177.
`4. In the seminar field, I have developed seminars about Windows 3.1,
`Windows 95, and Windows 98, networking PCs, and He]p Desks (i.e., technical
`computer support groups inside trediwn to large organizations), and have led teclmical
`seminars throughout the United States, Canada, and the United Kingdom, in association
`with Data-Tech Institute, since 1988.
`5. I am the author or coauthor of the fullowing books: Bulletproofing Windows
`98 (McGraw-Hill, October 1998); Windows 98 Registry For Dummies (IDG, 1998);
`Windows 95 Registry For Dummies (IDG, 1995); Small Business Networking For
`Dummies (IDG, 1998); Intranet Publishing For Dummies (IDG, 1997);
`Bulletproofing
`Windows 95 (McGraw-Hill, 1997); Creating Cool PowerPoint 97 Presentations
`(IDG,
`
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`1997); Bulletproofing Client/Server Systems (McGraw-Hill, 1997); Bulletproofing
`Net Ware (McGraw-Hill, 1996); Bulletproof Your PC Network (McGraw-Hill, 1996);
`and
`Exploding the Computer Myth (Wiley, 1995). I have a1so written several articles in
`computer and business magazines, and I have been interviewed by Computerworld,
`Mac Week, and Inc. magazines on business computing issues.
`6. As a video author, I have developed several long-funnat technical computer
`videos on subjects including Windows 95 and He]p Desk manageirent. I a1so
`contributed
`to the developtrent of several Internet-related computer videos.
`7. I am a Microsoft Certified Professionai certified specifically as a Windows
`95 Product Specia15t, Windows 95 Migration Specialist, and Windows 3 .1 Product
`Specialist I also have participated and am currently participating in a number of beta test
`program; (i.e., program; in which the creator of software products distributes pre(cid:173)
`re1ease
`versions of products to a limited set of users fur testing, experirrentation, and feedback),
`including Windows 98 and Windows NT 5.0. My current professional iremberships
`include the Am:rican Society fur Training and Developtrent and the Association fur
`Computing Machinery.
`8. I hold a Bachelor of Science in General Engineering ftom Stanfurd
`University, where I graduated with distinction in 1980. My course of study included
`computer science courses and engineering courses requiring computer programming. I
`have continued my teclmical education since then by attending seminars and courses on
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`Windows, networking, programming, comnmications, and the Internet
`
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`9. In October 1997, the Dep~ of Justice asked ire to provne consulting
`services regarding Windows 95 and Internet Exphrer. I have since provned services
`ranging from explaining features of Windows and Internet Exphrer to perfunning
`e:xperirrents and tests with those products, and other products, regarding features,
`design,
`reimvability, compatibility, and the user interface. I directed the creation of a videodi;c
`used in the January 13, 1998 contempt hearing, and testified in that hearing as to the
`results of my tests. I have provned infunmtion and comn~ntary to DOJ regarding
`corporate and end-user computing issues, as mich of my writing, teaching, and
`consulting concerns those subjects. I have comrrented on filed docummts (brieiS and
`depositions) in order to cJarify technical issues and provne insight relating to end user
`and corporate concerns with regard to operating system, browser, and other software
`products.
`10. ~ testimmyrelies upon the fuDowing sources ofinfunmtion:
`• My sixteen years' experience in the computer industry, including my own work
`with the Internet and multiple versions ofM:icrosoft's Windows operating system
`products;
`
`• Research that I have done in the course of writing eleven books, six seminars, and
`fuur videos;
`
`• Thousands of articles and books that I have read about computing and computers;
`
`• Conversations, both in person and by e-mail, that I have had with Windows
`software developers;
`
`• Conversations that I have had in seminar and consulting settings with hmdreds of
`computer professionals who work in the Windows and Internet fields, particu1arly
`
`with regard to issues of support and manageirent of networks of computer users in
`1arge- and tredium-s:iz.ed organizations;
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`• Interviews with corporate PC managers in which I have participated at the request
`of the Justice Departrrent;
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`
`• Summaries of interviews that DOJ representatives have conducted of corporate PC
`managers;
`• Research and experirrentation done at the request ofDOJ with diflerent versions
`ofWindows 95, Windows 98, Internet Explorer, and other software products;
`
`• My review of docurrents and deposition testirmny (of Microsoft employees and
`other witnesses) in the tmnths prior to t1m trial; and
`
`• My own experiences in custom, non-connre.rcial application software
`developmmt.
`
`11. The interviews in which I have participated at the request of the Justice
`Depart:Irent included top-level teclmology managers (Chieflnfurmation Officers, Vice
`Presidents oflnfurmation Services, and the hke) from the fulk.lwing organimtions:l
`Arre.rican Stores; Citibank; ConAgra; Federal Express; Florida Depart:Irent ofRevenue;
`GE Supply; Infurmix; J.C. Permey, Liberty Corporation; PJayboy, Morgan StanJey/Dean
`Witter; Sabre Group; and US Steel Group. The total mmlher of PCs under management
`by the individua1s I spoke with is approximately 246,500.
`
`12. The conversations that were sunnnariz.ed fur im by the Justice Depart:Irent
`included top-Jevel teclmology managers from the fuilowing organimtions: Boeing;
`Chrysler; Ford; John Deere; and Motoro1a. The total number of PCs under managerrent
`by the individua1s in this group is approximately 366,000.
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`III. DEFINING SOFTWARE PRODUCTS
`A. Given the different ways that software products can be
`compartmentali7.ed into files, the most reliable and useful definition for
`a software product is that product's feature set.
`
`13. Software is atmng the m>st abstract and clifficuh products to l.lllderstand
`and to define. Given the fuct, as I cmcuss in greater detail below, that software
`developers can commingle code units (subroutines) with other, unre1ated code units into a
`single DLL file on disk, it is imre appropriate, naturai and intuitive, to think of the
`imaning of "software product" as a mature set -- that is, what the user sees -- than as a
`fixed set of files.
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`14. Attempting to define software as a particu1ar collection of files is ultirmtely
`impossible if code units within the s~ file are shared, either by multiple applications or
`by a single application and an operating system For example, Microsoft's word
`processing software product, Word fur Windows, ships with the file COMCTL32.DLL,
`but that file is also used by Windows 95. Is the file COMCTL32.DLL part ofWord fur
`Windows, part ofWindows 95, or both? The answer is simple. Ifa file is relied upon by
`both products, then it is can be considered a ''part" ofboth, but it cannot be considered
`an
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`exclusive ''part" of either. Attempting to define software strictly as a collection of files is
`a :fruitless exercise when sonx of those files perlbrm double duty in c:liffurent contexts.
`As the director ofinfurmation technologies fur US Steel Group stated during an
`interview: ''You cannot iso1ate application code easily anytmre." Similarly, Scott Vesey,
`Boeing's Windows Web Browser Manager: ''You know, it beconxs very difficult to
`draw a specific line at which you've drawn a boundary between operating system and
`appfuation" (S. Vesey Deposition, 155:23-25.)
`15. Indeed, both industryproressionals and computer custotrerS think ofa
`software product IIDre as that which enables a set of related features than as a collection
`of specific files. For example, when a reviewer evabJates a software product in a
`computer tmgazine, the reviewer typically fucuses on that product's feature set: ''This
`product can do :X, but not Y," and so furth. The list of files that conx in the box, or the
`list of code units that those files contain, is rarely if ever provided. Similarly, when I
`teach computer concepts to users, I comrmnly hear users describe word processing
`software as a program that provides text creation, editing, and printing features. In my
`experience, users typically think of a browser as a program that provides Web page
`disp1ay and navigational features on the public Internet or a private intranet
`16. Consistent with my experience, Microsoft employees al<!o tend to describe
`software products in tenm ofreature sets. For example, Chris Jones, Microsoft's
`Product
`Unit Manager fur Internet Explorer, has described two of the products Microsoft
`associates with Internet Explorer as fuDows:
`
`Q: What is Outlook Express generally?
`A: It's a POP 3 mail client, POP3 and IMAP.
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`Q: What is N etMeeting generally?
`A: It's a set of services that let you do video phone and
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`video conferencing. (C. Jones Deposition, 80:2-4;
`140:18-19)
`
`Mr. Jones descnbed Internet Exp1orer, as deve1oped fur the App1e Macintosh operating
`system, in sinnlar tenm:
`Q: How then woukl you define what competitive browser
`fur other platforms, non-Win32 platforms, what that
`~ans?
`
`A: It's a very interesting conversation In so~ senses it's
`just what our custo~ expect and want from us. It's
`the thing that will let them go and dep1oy and take
`advantage of the services on the Internet and
`computing on the Internet So what does competitive
`browsing ~an, if you are asking~ what package we
`ship on the Macintosh, we'll ship a package IE5 that
`contains a set of features that peop1e can use to browse
`the Web, that ISVs can target and ICPs can target. (C.
`Jones Deposition, 116:2-14.)
`
`17. At the s~ ~' Microsoft executives have acknowledged the difficuhy of
`defining Internet Explorer according to :files or code. Most notably, David Cole, who has
`managed Microsoft's Internet Exphrer developmmt, stated in an internal e-tmil on
`January 2, 1998 (l=ss than two weeks prior to a hearing held by this Comt in which Mr.
`Cole testified) that:
`Taking out ail of ''retail IE" per the comt order renders Win95
`unbootabJe per my Jong affidavit. We can add :files back one
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`at a ~ and see what starts working, but I don't think there
`is PR or legal benefit of explaining that. There is controversy
`as to whether so~ :files hlce corrEill2.dil and others that
`were part of the original Win95 shoukl be fairly included on
`the list, but the comt said all of retail IE. Weve never sat
`down and decide [sic] what files are part of what, we just ship
`them where needed. (Exhibit 989, D. Cole m:ssage to B.
`Chase et al, January 2, 1998 [emphasis added])
`
`B. Typical PC users can only use software products that are loaded and
`readily accessible.
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`18. The existence of a software product on any particu1ar PC - that is, whether
`it is effectively present or absent from the custo~ standpoint - depends on both the
`presence of the software enabling the product's feature set, and the ~ans to use that
`feature set. Without the OEans of access, a typical user has no convenient way to use (or
`even determine the existence of) the software that exilts on a CD-ROM disc, PC hard
`drive, or floppy diskette. As John Kies, a Senior Product Manager at Packard
`BeIVNEC,
`bas testified:
`Q: We talked about the option as providing Packard
`BeWNEC with the option of rerroving the icon and the
`Internet Explorer from the start irenu. From a
`nmketing perspective, how does rerroval of the
`Internet Explorer icon and Internet Explorer from the
`start ~m affect whether or not customrrs perceive
`that the Internet Explorer is rerroved or not?
`
`A: WeD, if we provide it without Internet Explorer in the
`~item, the customrrs feel like there's no browser
`installed whether or not the actual code rmy exist
`below the surface of the user interface. So we wanted
`to give our customrrs the idea that they were receiving
`as c1ean an OS as we could provide them (J. Kies
`Deposition, 27:1-16.)
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`19. Jn met, it is possible, and SOOEt.:irreS a matter of C01.lllrel"C:ial practice, to
`have software that exists on a disk or PC in the sense that its code rrodules are
`physically
`present, but does not exist in any practical way from the user's standpoint because the
`software is hidden, protected, or otherwise diciabled. Consider the fullowing examples:
`• Philip Barrett, senior vice president ofRealN etworks, has described his company's
`RealPlayer software in these terms:
`
`Q: Focusing on the RealPlayer and the PlayerPlus, does RealN etworks
`distribute a version of the Player that includes the PlayerPlus
`features not activated?
`
`A: Yes. The way the Player and PJayerPlus are related is basically
`there's one P1ayer. P1ayerPlus features are activated by a license key
`that one gets by coming to our Web site and going through a secure
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`furm and purchasing that license key, ahhough they believe they are
`purchasing PlayerPlus.
`
`Q: So if a customer doesn't purchase this activation key, what does the
`userbave?
`
`A: The user has the standard, what we call, ubiquity PJayer, the free
`Player.
`
`Q: But as a technicalrmtter, does the user have the code that
`implemmts the PlayerPlus features?
`
`A: Yes.
`
`Q: Is it correct to say that even if a customer has the bits of code that
`tmke up the PlayerPlus, if the user does not have access to the
`PlayerPlus features, then, as a practical matter, the user doesn't have
`the PJayerPlus product?
`
`A: From the user's perspective, what they have is the standard PJayer.
`
`Q: ButnotPlayerPlus?
`
`A: Correct, not PJayerPlus.
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`Q: And that's because they're unable to access the P1ayerPlus features?
`
`A: That is correct (P. Barrett Deposition, lOn/98, 45:)
`
`• Adobe Type On Call is a CD that contains many typefuces, but the user nrust
`receive an alpba.tn.nreric password in order to unlock them This is the vendor's
`trethod fur ensuring that paymmt is received befure the user can work with any
`given typeface.
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`
`• Apple's QuickTirm Movie P1ayer is a program that p1ays back digitiz.ed rmvies on
`a computer screen As Tirmthy SchaafI: Senior Director of the Interactive Media
`Group withinApp1e, stated in his September 16, 1998 deposition:
`
`Well, the business rmdel that we have articulated for
`QuickTirm for the :last six rmnths or so has been a
`rmdel where people downhad the package of
`QuickTirm software for free. And then if they- and
`by spending a small amnmt of rmney, they can obtain
`an access key e:frectively that would llllhck additional
`capabilities. (T. SchaaffDeposition, 9/16/98, 455:5-
`11.)
`
`• A comrmn way of distributing software is by making ''trialware" or "shareware"
`:freely available on the Internet A custorrer can download a program and use it for
`a fixed period of tirre, say, 30 days. At the end of that tirre, in one comrmn
`scenario, the software may remain on the user's PC hard drive, but will no longer
`:function until the user pays a license fee and receives a password or a special
`small file that unk>cks the program Expired trialware or shareware physi:ally
`exists on the PC in tenm ofbits and bytes, but once expired, the program is
`e:frectively absent until the user pays for it.
`
`IV. CUSTOMER DEMAND FOR BROWSER AND OPERATING SYSTEM
`PRODUCTS
`
`A For a variety of Rasons, organi7ations generally value the ability to
`make application softwaR decisions independently from operating
`system decisions.
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`Page 12
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`20. OrganizationsZ typically evabate, purchase, tmnage, train, and support
`operating system software separately from application software. For example, operating
`system software evaluations and purchases nrust consider computer hardware issues to a
`much greater degree than application software evabations and purchases, as the
`operating
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`system typically "insulates" applications ftomhardware details. Consequently, based on
`my consulting and seminar experience, organizafuns generally value the ability to make
`application software decisions independently ftom operating system decisions. Indeed,
`the decision making process within most organizations is such that operating system
`software and application software decisions occur separately, either in titre - such as
`when an organization evaluates which applicafuns it needs first, and then selects the
`operating system Jater, or when an organization wishes to make application decisions
`across a variety of operating system; (as I discuss below) - or in tenm of who makes
`the
`decision (as is the case, fur example, at Atrerican Stores, Boeing, and US Steel Group),
`or both Conversely, no infurrmtion technology manager has ever told ire that he or she
`
`does not value the ability to make application software decisions independently ftom
`operating system decisions.
`B. Organizations' needs and expectations for browser products are
`fundamentally different than their needs and expectations for operating
`system software products.
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`21. Managers at many organizations (fur example, ConAgra, Morgan Stanley
`Dean Witter, J.C. Penney, Playboy, F1orida Departnxnt ofRevenue, Boeing, GE
`Supply) have to1d ire that they value the flexibility to make browser decisions
`independently from operating system decisions. For example, the CIO of ConAgra told
`ire on September 15 that his organization's choice ofWindows NT 4.0 was not affucted
`by the browser issue "at all" Sirmlarly, Boeing's Scott Vesey stated in his deposition
`that ''Those [browser standardimtion or browser acquisition] decisions have been made
`separately ftom operating system decisions." (S. Vesey Deposition, 104 9-10.)
`22. Organization managers have expressed that their needs and expectations fur
`browser products are fundamentally diflerent than their needs and expectations fur
`operating system software products. Managers typically (indeed, as fur as rm aware,
`universally) consider Microsoft Windows 95, Windows 98, and Windows NT in the
`category of operating system software. J Microsoft publicly characteriz.es these products
`as operating systems, and to my kmwledge has never charactemed them o~e.
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`Page 14
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`Conversely, organizations typically consider browser software as application software,
`like e-mail or word processing, not as an operating system or as part of a particular
`operating system I have recently heard or read this view ftom conversations or
`docummts ftomBoeing(see Exhibit 636, Boeing ''Desktop IntegrafunRoadmap"
`presentation (TBC 000348-000390)), ConAgra, Morgan Stanley Dean Witter, J. C.
`Penney, P1ayboy, Florida Depart:mmt ofRevenue, Boeing, and GE Supply. Technology
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`managers tend to be definite on this point, using phrases such as:
`''No question - the browser is the s~ type software as e-mail or ca1endar
`applications." (Steve Rue~ Morgan Stanley); or
`
`''The browser decision is the s~ kind of decision as an e-mail or word
`processing decision" (Paul KaDas, Playboy); or
`
`" ... browsers are considered by imst of om custorrers as a third party
`application" (J. Kies [Senior Product Manager for Packard BelVNEC]
`Deposition, 9/11/98, 25:10-12); or
`
`''In the s~ way that we woukl want to be able to choose what graphics
`editor or what H1ML editing product or what word processor we're using,
`we wouki want to be able to choose what Web browser we're using fur
`those s~ business reasons." (Scott Vesey [Boeing] Deposition, 104:19-
`23).
`Similarly, Dr. Michael Dertouzos, Director of the Laboratory fur Computer Science at
`MIT, and funrerly a Microsoft witness in this case, made this point quite clearly dlll"ing
`deposition testitmny in thl; case on October 2, 1998:
`Q: Is a browser an application?
`
`A: Historically and today, it is the case that browsers are treated as
`applications. (M. Dertouzos Deposition, 10/2/98, 36:1-2.)
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`I am not prepared to opine about the irmards of any of these systems
`today as to how well they do one thing or another. However, there is
`a definite diffurence between the comnands used by browsers and
`the commmds used by operating systems. These are two diflerent
`wor1ds that are always in two diffurent lmtorical contexts. (Id. at
`47:14-21.)
`
`No corporate PC tmnager, in met no one outside of the Microsoft orgatriz.ation, has ever
`described a Web browser to nx as operating system.software or as part ofWindows 95
`or
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`any other operating system
`C. Managers in organin.tions that do desire or require browser software
`on PCs deployed throughout their organin.tions commonly express
`many reasons to prefer one specific browser over another, and these
`reasons generally do not correspond or relate to their choice of
`particular operating system1.
`
`23. Organizations' needs fur operating system.and browser software also diffur
`with respect to the pervasiveness of need fur each type of software within the
`organization Whereas all organizations require an operating system in order to address
`even their m>st basic computing needs, not every organization needs browser software.
`Internet and intranet browsing is a less universal computing need than, say, being able to
`type infunnation at a keyboard. (An intranet is a private computer network that uses
`Internet technologies such as Web servers and browsers.) For so~ organizations, a
`demmd may exist to have no browser on the PCs of all or so~ employees. Based on
`my
`experience and my interviews, I am aware of several reasons why this is so~t:irres the
`case:
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`a. An organization may wish to make it difficult fur certain employees
`to access the public Internet, in order to reduce the am>unt of unproductive t:irre
`employees spend "surfing the 'Net" on subjects unrelated to their jobs. Without a
`browser, accessing the Internet's Workl Wide Web is impractical
`b. An organization may wish to min:i:tnil.e computer resource use (disk
`space, ~ry, CPU power, etc.). Unused applications that reside on a computer
`typically tie up such resources. The degree to which this is a concern typically
`depends on the average age of an organization's computers; the older (and
`therefure poorer in resources) the computers are, the greater the organization's
`desire to avoid wasting those resources. As Microsoft's Joe Belfiore has testified:
`Because a PC system is a shared set of resources, ~ry
`and processor are shared ammg all the d:ifrerent pieces of
`code that may be ruming at any t:irre. If any one piece of
`code is ta1cing up tmre of the shared resources than it needs
`to, then it will impact the perfunnance of the other pieces of
`code ... The tmre we can free up ~ry and processor so
`that other applications get m:>re of those resources, the raster
`those other applications willnm. And that's not specific to
`om code; that's true of any code." (J. Belfiore Deposition,
`138:4-18.)
`
`Resource use is often a concern with.programs as Jarge as Internet Explorer. For
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`example, a November 1997 iretm from Microsoft's Clnis Jones to the IE Project
`Team states:
`The IE4 browser, while fast, is simply too big fur custoirers
`to install and adopt, both in term; oftmm>ryusage [working
`set] and also in term; of disk fuotprint [install sire]. (Exhibit
`364 (MS7 0004717-4728).)
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`Later in the sa.tm mmn, Mr. Jones cites ''retmve sire/perfunnance issues
`(working set and installs~)" as one of three top product requests corporations
`made to Microsoft in cormection with Internet Explorer 4.0.
`c. An organization may wish to simp1ify the standard PC setup to the
`greatest possible extent, fur ease of configuration, use, docmrentation, and so
`furth. For exmJllle, Microsoft's Ja.tms A1Ichin alluded frequently in his March
`1998 deposition to the importance of simplk:ity in computer configurations:
`Reduce concepts is soirething that we've been trying to drive
`because of simplicity. It's just too complicated fur end users
`and we want to simplify the system (J. Allchin Deposition,
`3/19/98, 20:9-12.)
`
`My experience is that corporate technok>gy managers do indeed value simplicity.
`Section VI.A of this testiimny discusses standardization benefits in tmre detail
`d. An organimtion rmy wish to minimize the support costs associated
`with having "extra" undesired software on the typical PC. Those costs include
`answering user questions, troubleshooting software problem;;, training technicians,
`and so on
`24. For organizations, it is not always or even generally true that "any browser
`will do" just because it coires bund1ed with a part:£u1a.r operating system Managers
`have expressed a variety of reasons why this is the case.
`a. Perhaps rmst notably, an organimtion with muhiple operating
`systems already in use may prefur a part:£u1ar application because it can work on
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`each of those operating systems, enabling users throughout the organization,
`regardless of the operating system installed on their PCs, to use an organization
`standardiz.ed product to access the Internet and/or the organization's Intranet. In
`my interviews over the past two tmnths, soim managers (including those at
`Infurmix, Ford, Federal Express, Boeing, and Morgan Stan1ey/Dean Witter) have
`stated that their organizations depk>y a variety of operating systems and hardware
`platfunm, and therefure prefur a browser having greater cross-platfurm availability
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`and compatibility.
`• A Morgan Stanley/Dean Witter manager listed several reasons that his
`organization p1aces great value on cross-platfunn applications: less training
`expense, less testing expense, tmre e:frective internal cormnmications via e-mail,
`less application testing, tmre efficient user services, and lower Help Desk costs.
`
`• Scott Vesey ofBoeing makes the following conn:rents:
`
`Q: One of the things that you testified about befure was the met that at
`Boeing there are PCs and workstations that nm not only Windows
`but various funns ofUnix and in sorm cases the Mac operating
`system Is that right?
`
`A: Yes, that's true.
`
`Q: Okay. Is it important in your evaluation and in Boeing's ultiimte
`choice ofbrowsers that the browser chosen be able to nm across an
`of those p1atfunns?
`
`A: We've seen that as being sotret:hing that we believe to be
`advantageous. (S. VeseyDeposition, 88:13-22.)
`
`MX:rosoft executives recogrme this preference. As Chm Jones stated in one
`internal Imtm:
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`Cross p1atfunn adoption continues to be a major adoption
`hurdle. Many corporations and ISPs will not deploy our
`products until the cross platfunn products have shipped. Sim
`[simultaneous] shipping a lower featured cross p1atfurm
`product is better than shipping 1ater with tmre features
`
`What would success look like? Sim ship (<=4 weeks) IE+
`key components on key platfunns with a clearly articulated x(cid:173)
`p1at [sic] conn:mn, competitive feature set/user interfuce
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`where appropriate/admin and deploymn (Exhibit 364, C.
`Jones IlXlW to IE Project Team(MS7 004717-28).)
`
`b. Other mmagers (for example, at Federal Express and Chrysler) have
`tokl rm that they consXler the strategic direction of the browser ven