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Trip Report: Nader's conference on Microsoft
``` [I've enclosed Cem Kaner's report on the "Appraising Microsoft" conference. I particularly recommend Cem's own paper (which is not focused specifically at Microsoft) on impending changes to the Uniform Commercial Code that are strongly biased in favor of software vendors. Those who are studying the legal issues in the Microsoft Wars may also benefit from a new law review article by Bryce J. Jones II and James R. Turner, Can an operating system have a duty to aid its competitors?, Jurimetrics 37(4), 1997, pages 355-394. Several people have sent me URLs for useful online news articles about the Microsoft Wars, but I have managed to lose them all. If you resend them by early next week, I'll package them for the list. And anyone else with URLs for high-quality reports on the subject are invited to send them along.]
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Date: Mon, 01 Dec 1997 05:05:27 -0800
From: Cem Kaner
Two weeks ago, I was a speaker at Ralph Nader's "Appraising Microsoft" conference in Washington. This is my trip report. This memo is a set of conference notes, not a scholarly or research paper. The conference itself is now at http://www.appraising-microsoft.org. (You can download the conference on real audio. There are a few bugs in the recordings, so maybe you'll wait for a few days after I send this memo.)
My own paper was on competition within the software industry in general, focusing on how the Uniform Commercial Code revisions will reduce competition. My belief is that this statute, if enacted, will have a greater long term anticompetitive effect than anything done by Microsoft. You can find my paper at http://www.badsoftware.com/nader.htm.
I don't have an axe to grind for or against Microsoft. I do business with them, with their competitors, and with some of their (some satisfied, some dissatisfied) customers. Overall, I've been impressed with the company and with their products. On the other hand, Ralph Nader is a hero of mine. I work regularly with Todd Paglia, the lawyer that Nader has assigned to monitor the Uniform Commercial Code software law proposal. I consider him a friend, and trust him. Paglia's boss, Jamie Love, was the primary organizer of the conference and has turned into a harsh critic of Microsoft. I've seen Love's work on some other issues and consider it excellent. He has high credibility with me.
Personal computing put tremendous power into the hands of individuals. Microsoft is one of several companies that helped create this information processing revolution, bringing the power of computers to "the rest of us." Microsoft certainly profited from this, it was definitely part of the movement to empower individuals with computers. Watch IBM/Lotus's "Work the Web" commercials and you'll see the contrast that I have in mind between companies like Microsoft and Apple and companies that saw small computers as an extension of the centralized computing mandarinates that served the huge organizations that could afford them.
At many levels, I look at the dispute between Nader and Microsoft as an unfortunate quarrel between organizations that should be friends.
These notes reflect my biases, but they don't try to spin the conference favorably toward Microsoft or Nader. Nor am I going to try to tell you who is right or wrong in this dispute. I don't know. My goal instead is to look for a rational basis underlying the heat and spin we've been seeing.
=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D Economics =3D=3D=3D=3D=3D=3D=3D=3D=3D=3D
I'm not an economist. Maybe you've heard of network effects and tipping and the phenomenon of increasing returns, but these expressions were new to me. I've seen the effects, but not the scholarly discussions. Nader's conference included a couple of economists (you can see the list of speakers at http://www.appraising-microsoft.org) who walked us through this.
I've talked with several folks about this conference over the past two weeks, including several who are very sympathetic with Microsoft's position. One comment that I've heard a few times is, "So what? What's wrong with a monopoly?" My answer is that the US economic and business regulatory structure is based on a fundamental assumption of competition in the marketplace. Competition drives prices, quality, and ongoing efforts to satisfy customers. It is a fundamental spur to innovation. I'm not going to walk through the evils of monopolies--read a university textbook on economics, like Samuelson, and you'll get the picture. I've been told that Microsoft would never commit the worst abuses of monopoly power and I'm far from being convinced that the current Microsoft management would commit those abuses. But monopoly power lasts a long time. Companies change over time. WordStar changed after it imported management from Sperry to take it public. Apple changed after it imported a president from Pepsi. Corporate cultures change.
It also bears mention that Microsoft is far from being the only business that the Department of Justice has made antitrust cases against. For a list of current cases (with descriptions and official documents), see http://www.usdoj.gov/atr/cases3/.
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The main antitrust laws in the US were written near the turn of the century. William Howard Taft and Teddy Roosevelt, for example, were famous TrustBusters. These laws were based on assumptions about how monopolies were created and sustained that aren't always correct. In particular:
(a) there's a bias that competition within a market is a good thing--it's better to have three companies at 30% market share than one supremely dominant company (say, 70-90% market share) with one or a few powerless competitors.
(b) Another example is the (economic) law of diminishing returns. When a company supplies a product, its per unit costs might initially decline (economies of scale), but eventually they rise as you exhaust the local pool of labor and other resources.
These assumptions don't always fit an information economy. Laws based on these assumptions have to be carefully applied or we will have bad results.
(1) Network Effects
If you're the only person in the world with a telephone then it's not very useful. You can't call anyone. As more people get phones, the value of each phone increases. This is the "network effect."
The network effect creates a powerful push toward a standard. Think of the VHS versus Beta competition. Some movies came in beta, some in VHS, some in both. The total selection of movies in stores was depressed by the fact that stores had to keep double inventory (beta and VHS). When consumers figured out (however they figured it out) that VHS was going to be the winning format, they flocked to VHS and abandoned beta. This phenomenon is called "tipping" (like, tipping the scales). The result was that lots more movies were available on VCR and so even fewer people bought beta. Result: beta is history.
There are two types of competition--competition IN the market and competition FOR the market. Competition IN the market is like Ford vs. GM. They both make cars. The popularity of Fords doesn't disproportionately reduce the value of GM cars. Both might be able to sustain a 30% market share for a long time.
Competition FOR the market is like VHS vs. Beta. There's a network effect. The more people who adopt one format, the more movies there will be for that format, the more VCR players, etc. The weaker standard dies.
I am often told that beta was the technically better standard. Let's suppose this is true. The defeat of beta by VHS illustrates another aspect of network effects--competition doesn't necessarily pick the best product or standard. Dominance goes to the one that is marginally or apparently more popular, whether it is better or not. (No buyer wants a technically superior VCR that can't play any of the new movies.) There is nothing sinister about this. Eventually, the market collectively makes a decision. Adopting a lesser standard can be much more efficient than continuing to fight over which not-yet-a-standard is best.
Several things that we (mass-market software publishing staff) know about marketing fit into this model. If the goal is to capture the entire market by virtue of creating a public perception of dominance in the marketplace, then tactics like these are important:
(a) being first to market
(b) cutting a competitor's first-to-market advantage by announcing really cool vaporware
(c) other strategic advertising that undercuts competing products at critical times
The market for operating systems is a network-type market. If an operating system is perceived as relatively unpopular, fewer people will write applications for it, fewer people will make or sell computers to run it, fewer third party support organizations will form to support it, fewer schools will teach it, fewer employers will expect experience with it, etc.
In a network-type market, it is no surprise to see one company with a 90% market share. If three companies (who make incompatible products that follow incompatible standards) had 30% market shares, we would probably look at the situation as unstable, rather than as desirable. If people ever come to perceive one of the competitors as more popular than the others, it will skyrocket in popularity, and the popularity of the others will decline.
There are several estimates of Microsoft's share of the operating system market. My understanding is that 90% of the world's computers run Microsoft Windows. That's well beyond the 70% threshold often used to class a company as a monopoly. But we should expect this as a normal consequence of the operating system market. SOMEBODY has to own the OS market. It just happens that this week, the owner is Microsoft.
Competition in the OS world is competition by paradigm shift. We should expect the successful competitor to Windows to displace it, not to peacefully co-exist with it.
Of course, many operating systems could compete with each other if we changed the nature of OS's or applications to make them more compatible. To illustrate the point, there was a time when document transfer between MS Word and WordPerfect didn't work. That incompatibility created a need to standardize on one product or the other. Today, you can have WordPerfect, I can have Word, and we can co-author a book. The difference in file formats is a nuisance, but it's not a huge deal.
So another way that MS could lose its monopoly on the OS market would be a magic wand that lets applications run on any operating system. At this point, different people could run different operating systems without much loss of benefit. (Some people think this magic wand's name is JAVA.)
(2) Increasing returns
The argument was made at Nader's conference that in the software world, the marginal cost for new copies of the software is relatively small. The main cost was the R&D cost in birthing the puppy. The per-customer cost of support declines as more people call in (the ansswer books are cheaper to research and write, plus the network effects. The company that is established in a field has a cost advantage over a smaller or newer player.
Therefore, a company that is selling many copies of its products will have a cost advantage over a smaller competitor.
I'm not sure that I buy this. In many companies (Microsoft seems to be a remarkable exception), the collective corporate IQ seems to be inversely related to the company's size.
=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D The Threat =3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D
I'm not an antitrust lawyer; some of my comments on antitrust law could be naive or downright mistaken. Similarly, I am not intimately familiar with the fights between Microsoft, Sun, Sybase, etc.
We start from the fact that Microsoft has a monopoly on operating systems of currently sold machines. There isn't necessarily anything wrong with this, but it gives cause for concern if Microsoft abuses the power that it gains out of the monopoly.
The notion of "Monopoly Leveraging" runs as follows:
A traditional claim for monopolization occurs when a firm uses its monopoly in one market to actually monopolize another market, or to grab most of that market. Monopoly leveraging doesn't require full monopolization yet. Instead, this occurs when a monopolist in one market uses that monopoly to gain a competitive advantage in another market. It's probably the case that current courts will require evidence that the monopolist is attempting to use leveraging to gain an advantage that will turn into a monopoly.
It was repeatedly stressed at the conference that it is important for Microsoft to expand into new markets because (it was said) their business model depends heavily on rapidly expanding revenues and a rising share price. Microsoft's market valuation is huge. To keep the stock price rising will be be very challenging. The analogy that was repeatedly drawn is that Microsoft is like a great white shark. It has to keep moving and it has to keep feeding.
You don't have to agree with this assessment of Microsoft's situation to understand that there are a lot of businesses out there who feel like endangered smaller fish. The shark analogy expresses a genuine fear.
Microsoft has been expanding in three areas that have caused concern:
(a) Applications
Microsoft now dominates the market in word processing, spreadsheets, and several other applications. It is not unlawful for MS to dominate the Office market if it got there simply by making better products and marketing them better.
Arguments have been made that MS gives its internal applications groups more information about the operating system than it gives to competitors, making it faster, easier and cheaper to produce application software at MS than it would be to produce equivalent software at a competitive company.
It's important to recognize something here. Whether or not MS withheld information unfairly, or used private information unfairly, there are many people who firmly believe this is true, and they have a rational basis for that belief. Just as the shark analogy is a noteworthy expression of genuine fear, the undocumented DOS (etc.) discussions reflect genuine anger.
I didn't hear a serious claims that there is enough evidence to support a lawsuit for monopolization in the application market. But a red flag goes up, and should go up, when a monopolist gains dominance in second, third, and umpteenth markets.
(b) On-line Industries
Microsoft is expanding into several on-line sales situations, such as Expedia and sidewalk.com. The concern is that these services will become the dominant services within their categories.
It certainly is not, and should not be, unlawful for MS to expand into on-line markets. The concern is that Microsoft is using its dominance in the operating system market to give itself a leg up on this.
The problem is the use of the channel bar in IE 4. When you install IE 4, this appears on your desktop. You can click one to arrange travel, for example. You have a choice of on-line travel agencies, but the first choice presented is Expedia. Travel agencies have a lot of experience with on-line travel reservation systems. In fact, these have been the subject of antitrust action themselves. On the old systems, you'd see all the United Airlines flights first, or all the American flights first (or whatever--depends on whose system you were using). Even though a better priced flight or a better timed flight might appear later in the list, over 50% of the flights sold were the first ones listed on the screen and over 90% appeared on the first screen. Whoever presented their information first got the sale.
By controlling the desktop, Microsoft can arrange so that its information conmes first in any competitive listing of online services.
As another note, Nathan Myrhvold, Microsoft's Chief Technology Officer, said that Microsoft wants to collect vigorish on every transaction over the internet that uses Microsoft technology. (See Wall Street Journal, June 5, 1997, "Microsoft Moves to Rule On-Line Sales.") "Vigorish" refers to a fee for bringing the two parties to the transaction together. ("Vigorish" is an interesting word to use. I've always and only heard it used in connection with gambling or with organized crime. It's not the best word to use if you want to win the hearts and minds of a bunch of prosecutors.)
(c) Content
Microsoft is moving into online and broadcast content into ways that some people find disturbing. One concern is whether MS is likely to abuse its entry into content.
Microsoft's Encarta is now the world's best selling encyclopedia, derived from (blech, ptui) Funk & Wagnalls. Encarta is certainly much improved over the original, but it is a testimonial to Microsoft that it can turn Funk & Wagnalls into the bestseller.
One of the more amusing tidbits at the conference involved comparing an old Funk & Wagnalls entry for Bill Gates with Encarta. According to one of the speakers, both entries were quite similar, except for a final sentence. In F&W, Gates is characterized as a determined competitor. In Encarta, that goes away and he said to be best known for being a philanthropist, making big donations to charitable causes.
Whatever the full story is behind the Encarta entry, we all know that companies often say nice things about themselves and their executives. Big deal.
Microsoft responded in surprising detail on this point. This is one of (only) 7 "myths" that Microsoft claims to have "debunked" at http://www.microsoft.com/corpinfo/myths.htm. According to this press piece, Microsoft wrote both entries. The identification of Gates' charitable work was merely an update. (Confusing everything, MS quoted from Encarta 98 to illustrate its point, but I think the speaker used Encarta 97.)
This illustrates a problem in interpreting so much of this material. When I read the MS response to the Department of Justice papers, at http://www.microsoft.com/corpinfo/11-10Filing.html, some of it seems like real baloney. On the other hand, some of the statements made by MS critics are plenty questionable too.
A frequently repeated claim during the conference was that MS abuses its power by threatening publications that it will pull advertising if they publish certain pieces. Some of these claims were nonspecific and I finally rose to challenge speakers to either be specific on this charge or to stop making it. (The audio for some of this is at http://www.appraising-microsoft.org/day2rm.html. I spoke in the Questions section of the Government Antitrust Enforcement Activities, at minute 9:53 of the RealAudio clip). Graham Lea responded that he had personally been a victim of this and that Bill Zachmann (spelling?), formerly of PC Week had also been a victim of this and that Microsoft had publicly admitted it. Two additional speakers, John Perry Barlow and Wendy Goldman Rohm, were quite specific in these types of claims. You can hear more details in the recordings of their talks, at http://www.appraising-microsoft.org/day2rm.html, in the Microsoft and the Media section.
If these claims of pressure on the media are true, then I think that concerns about the fairness of news coverage by companies owned by Microsoft are well justified. I'd be more interested in a detailed MS response to this one than to the attention they paid to that silly example from Encarta.
=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D The Lawsuits =3D=3D=3D=3D=3D=3D=3D=3D=3D=3D
Microsoft has a lock on the operating system market until and unless someone else takes it away from them.
Three different actions were discussed in detail at Nader's conference:
(a) Caldera's lawsuit alleging monopolization in the DOS market. http://www.caldera.com/news/npr/complaint.html (I haven't found an online source for the response from Microsoft.)
(b) The Department of Justice action over the bundling of (or integration of) Internet Explorer 4.0 with Windows 95. http://www.usdoj.gov/atr/cases3/micros2/1236.htm http://www.usdoj.gov/atr/cases3/micros2/1237.htm http://www.usdoj.gov/atr/cases3/micros2/1277.htm http://www.microsoft.com/corpinfo/doj/doj.htm http://www.essential.org/antitrust/microsoft/microsoft.html
(c) Sun's lawsuit alleging breach of contract involving JAVA. http://www.sun.com/announcement/counterclaimdoc2/ http://www.sun.com/smi/Press/sunflash/9711/sunflash.971118.1.html http://www.microsoft.com/corpinfo/java.htm
I'm going to start with the Caldera suit.
(a) The Caldera / Digital Research Lawsuit.
Digital Research invented CP/M, which was one of the operating systems in common use before IBM PC's came onto the market. IBM chose Microsoft, not Digital Research, to create an operating system for the PC. MS supplied MS-DOS and PC-DOS for Intel-based machines. DR published CP/M-86, Concurrent CP/M-86 and Concurrent DOS for this market. Later, it published DR DOS, at a time when MS appeared to have a lock on the PC OS market. Its sales, especially of DR DOS 5.0, were significant but they eventually diminished. In this period, Digital Research sold itself to Novell, which eventually sold the DOS operating system and related assets to Caldera. Caldera sued MS for antitrust violations related to the competition between MS-DOS and DR-DOS.
Caldera did a remarkably good job of presenting its case at the conference and in its complaint, bolstered with information from Andrew Shulman (Undocumented DOS, etc.).
I was surprised by the strength of the presentation because I'm a skeptic about this suit. I started doing testing in the DOS applications market in 1983 and had experience with some of the early 8086 offerings for PC's, plus later experience with DR DOS 5. I didn't develop a lot of respect for these offerings. As to Novell, the other acquisition that I think of when I think of Novell is WordPerfect (which I used in preference to Word until I gave up on getting a reliable Windows version.) You'll recall that Novell bought WordPerfect for about $1.1 billion and sold it for about $100 million a year later. Maybe Novell had a bit to do with the failure of DR-DOS too.
Despite my opening bias, I think that Caldera makes a few points that are worth considering.
First, MS set up a per-processor license agreement with OEMs. If you made such an agreement with MS, then you paid for a DOS license for each computer you sold, whether you bundled DOS with that particular machine or not. I remember discussion of this at the time that MS was selling these licenses. The problem that I remember was that several companies were selling compuers with pirated copies of MS-DOS. This agreement was a simple method for resolve some serious disputes. I have no idea whether MS even thought about or cared about Caldera (then DR) in creating this licensing arrangement. I wouldn't be at all surprised to learn that MS worked out the arrangement without any consideration of DR, one way or another. However, the result was apparently to the detriment of DR's sales.
Second, MS put code into at least one beta version of MS Windows that gave an error message on detecting DR DOS (or on not detecting MS DOS) as the operating system. According to Caldera's complaint, MS made it clear that Windows 3.1 would not be compatible with DR DOS. If this is true, then I would expect OEMs to avoid DR DOS. Again, I think that there's an interesting question of intent here. A smaller company building a beta test version that would widely circulate might well build environmental checks into the product that are more restrictive than the final product, and it might well do that without documenting this to the beta testers. The fact is that in beta testing, like all other testing, there are only so many variables that you want to be manipulating at once. Forcing some temporary simplifications on the world is not unreasonable.
It's entirely plausible to me that MS acted relatively innocently with respect to DR DOS, perhaps refusing to make allowances for DR DOS, but not actively seeking to harm DR.
The problem is that it doesn't matter to a cockroach whether you're actively seeking to harm it or not. If you step on it, you squish it. If you have monopoly-sized shoes, you're required to look where you're going.
Caldera makes other points, more sympathetically to its case.
(b) Bundling of Internet Explorer 3.0 / 4.0
Government action is partially a response to law and partially to public opinion. To the extent that the DOJ -- or any other antitrust agency -- perceives significant and rational public fear and anger over a problem, that agency will seriously consider getting more active in a dispute that is clearly within its domain.
Here's the language of the consent decree that Microsoft agreed to, and which was entered by a federal court as a Final Judgment on August 21, 1995. This settled the last dispute between MS and DOJ (the Justice Dept).
E. Microsoft shall not enter into any License Agreement [with an OEM] in which the terms of that agreement are expressly or impliedly conditioned upon:
(i) the licensing of any other Covered Product, Operating System Software product or other product (provided, however, that this provision in and of itself shall not be construed to prohibit Microsoft from developing integrated products).
Unfortunately, the decree doesn't define "integrated products."
Is IE an integrated part of the operating system, in which case it is appropriately bundled with Windows 95, or is it a standalone application, in which case compulsory bundling with IE is probably unlawful under the agreement/consent decree? (Unlawful, because MS requires OEMs to include IE with Win 95).
You have to decide the anwser to that question.
What's not in dispute is that MS thinks that browser war is critical to MS because a high-functionality browser can replace much of the functionality found in a high-functionality operating system. For example, here is this, from MS's response to the Justice Department's (DOS's) petition:
As the DOJ notes (see, e.g., DOJ Mem. at 32), strong and well-financed competitors of Microsoft such as Sun Microsystems and Netscape are seeking to render Windows 95 and other Microsoft operating systems obsolete by creating so-called "middleware" layers that obscure the underlying operating system. Apparently in the DOJ=92s view, Microsoft should be forced to sit on its hands while competitors attempt to take away one of the most important aspects of Microsoft=92s business.
We used to have a model of operating systems that including a relatively thin operating system layer, then a user interface layer (such as windows), then an application layer. Win 95 erases the separation between the system layer and the UI layer. Win 98 will erase a separation between the system and an application, the browser.
How far does this go?
As far as I can tell, MS' position is that it goes as far as MS wants it to go. If MS wants to integrate the word processor, spreadsheet, desktop publisher, and lots of computer games into the oerating system, that's none of the Department of Justice's business.
I don't think that it makes technical sense to stretch the definition of "integrated" this far. But as to what's allowed under the consent decree, enjoy your reading.
(c) Sun v. Microsoft
The story goes that Java is a perfectly cross-platform language. Write a Java program once and you can run it on a bunch of different machines, without modification. I don't program in Java and I have no independent knowledge of the truth or falsity of this claim. Some colleagues tell me that it's reasonably close to true, others tell me that there are some significant problems.
Let's suppose that Java really is platform independent.
Sun claims that IE 4.0 and Microsoft's SDK for Java are not compatible with Java. In the language of the complaint:
The "SignatureTest" results show that the set of public APIs for the "java" class libraries implemented in Microsoft's IE 4.0 have been modified by Microsoft to delete various classes to the "java." class hierarchy, and to add and delete various methods and fields in the "java" class declarations. Schroer Decl. =B615. These non-conforming modifications were not previously disclosed to Sun by Microsoft and result in the failure of IE 4.0 to pass the JCK 1.1a "SignatureTest." Id. =B6 17.
In addition to IE 4.0's failure to pass "SignatureTest," it also fails to pass any of the 343 required tests for the RMI class library, and all 239 required tests for JNI.
In terms of the significance of this dispute, Java could be the language that will allow competitors of MS to create an application layer that is largely independent of the underlying operating system. This is the same issue as the one I mentioned above, with the browser.
If it doesn't matter what the underlying operating system is, then on an Intel platform it could as well be an updated version of DR DOS as Windows 95.
=3D=3D=3D=3D=3D=3D=3D=3D=3D Remedies =3D=3D=3D=3D=3D=3D=3D=3D=3D=3D
So what are the people asking for?
Well, Caldera wants lots of money. Maybe some other court orders too.
A few extremists spoke of exterminating Microsoft, but I don't think that this is the goal of the antitrust actions.
Most of what I heard involved some fairly simple demands:
(a) Let OEMs sell MS Windows 95 without showing the IE icon. If they prefer to steer people to Netscape, or to require customers to download the browser of their choice, let them.
(b) Let Sun define Java. Microsoft shouldn't screw around with this definition, because that creates a risk that Microsoft will be able to sabotage, rather than fairly compete with, its competition.
(c) MS should be required to share OS information with competitors, to the extent that it uses this information in the development of its own products. (This one will be tough. Even if MS wants to do this, the paperwork load of assuring that it is always done is not going to be minor, and it may force MS to change its development practices in ways that interfere with its ability to do good work quickly.)
(d) Something (I don't know what) should be done to make sure that the IE 4 channel bar doesn't give MS-based services an unfair advantage over the others.
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Well, that's the end of my report. I hope that you found it interesting and/or useful.
-- Cem Kaner
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Cem Kaner, J.D., Ph.D. Attorney at Law P.O. Box 1200 Santa Clara, CA 95052 408-244-7000 Author (with Falk & Nguyen) of TESTING COMPUTER SOFTWARE (2nd Ed, VNR)
This e-mail communication should not be interpreted as legal advice or a legal opinion. The transmission of this e-mail communication does not create an attorney-client relationship between me and you. Do not act or rely upon law-related information in this communication without seeking the advice of an attorney. Finally, nothing in this message should be interpreted as a "digital signature" or "electronic signature" that can create binding commercial transactions. ```
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