United States v. Microsoft Corp. (1998)
United States Court of Appeals for the District of Columbia Circuit
147 F.3d 935 (D.C. Cir. 1998)
After Microsoft (defendant) established a dominant share of the operating-system market, a 1995 consent decree barred it from conditioning Windows sales on purchasing a separate software product, while still permitting genuinely integrated products combining different functionalities. When Microsoft began bundling its Internet Explorer web browser into Windows 95, the government sued, alleging this bundling was really a tying arrangement forcing Windows purchasers to use Internet Explorer and giving Microsoft an unfair browser-market advantage. The district court issued a preliminary injunction against the bundling, and Microsoft appealed.
Whether, for purposes of antitrust law, a product with two or more functionalities is integrated if the functionalities are combined by the seller in a way that offers clear advantages to the buyer.