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Bill Gates

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          1                   UNITED STATES DISTRICT COURT
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                              FOR THE DISTRICT OF COLUMBIA
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          2
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              ______________________________
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          3   UNITED STATES OF AMERICA,     :
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                        PLAINTIFF,          :
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          4                                 :
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               VS.                          :    C. A. NO. 98-1232
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          5                                 :
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              MICROSOFT CORPORATION, ET AL. :
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          6             DEFENDANTS          :
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              ______________________________:
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          7   STATE OF NEW YORK, ET AL.     :
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                        PLAINTIFFS          :
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          8
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                VS.                         :    C. A. NO. 98-1233
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          9                                 :
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              MICROSOFT CORPORATION, ET AL. :
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         10             DEFENDANTS          :
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              _______________________________
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         11                                      WASHINGTON, D. C.
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                                                 NOVEMBER 16, 1998
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         12                                      (A. M. SESSION)
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         13                      TRANSCRIPT OF PROCEEDINGS
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                         BEFORE THE HONORABLE THOMAS P. JACKSON
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              COURT REPORTER:               PHYLLIS MERANA
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         20                                 6816 U. S. COURTHOUSE
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                                            3RD & CONSTITUTION AVE., N.W.
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         21                                 WASHINGTON, D. C.
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                                            202-202-202
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                         --- EXCERPT OF DEPOSITION TRANSCRIPT ---


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          1             QUESTION:  YES.  THE INDUSTRY AND MICROSOFT TRACKS
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          2   WHAT IS REFERRED TO AS BROWSER MARKET SHARE; CORRECT, SIR?
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          3             ANSWER:  NO.
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          4             QUESTION:  NO?  DOES MICROSOFT TRACK BROWSER
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          5   MARKET SHARE?
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          6             ANSWER:  I'VE SEEN USAGE SHARE.
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          7             QUESTION:  YOU'VE SEEN USAGE SHARE?
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          8             ANSWER:  UH-HUH.  BUT NOT -- MARKET SHARE USUALLY
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          9   REFERS TO SOMETHING RELATED TO -- NOT TO USAGE.  AND WITH
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         10   BROWSERS, I'VE SEEN MOSTLY USAGE.  NOW, SOME PEOPLE MIGHT
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         11   REFER TO THAT AS A MARKET SHARE, BUT IT'S NOT A MARKET
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         12   SHARE.
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         13             QUESTION:  WHAT IS A MARKET SHARE?
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         14             ANSWER:  WELL, WHEN I THINK OF A MARKET SHARE, I
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         15   THINK OF WHERE YOU'RE COMPARING THE REVENUE OF ONE COMPANY
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         16   TO THE REVENUE OF ANOTHER COMPANY.
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         17             QUESTION:  THE TOTAL REVENUE OF A COMPANY?
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         18             ANSWER:  NO, THE REVENUE RELATED TO ONE COMPANY'S
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         19   PRODUCT TO THE REVENUE OF ANOTHER COMPANY'S PRODUCT.
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         20             QUESTION:  AND THAT'S WHAT YOU THINK OF WHEN YOU
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         21   USE THE TERM "MARKET SHARE"; IS THAT YOUR TESTIMONY?
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         22             ANSWER:  USUALLY.
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         23             QUESTION:  ARE YOU AWARE OF DOCUMENTS WITHIN
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         24   MICROSOFT THAT DESCRIBE BROWSER SHARE AS THE COMPANY'S
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         25   NUMBER ONE GOAL?
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          1             ANSWER:  NO.  I'M AWARE OF DOCUMENTS WITHIN PAUL
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          2   MARITZ'S GROUP THAT MAY HAVE STATED THAT.
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          3             QUESTION:  IS PAUL MARITZ'S GROUP WITHIN
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          4   MICROSOFT?
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          5             ANSWER:  YES, BUT HIS -- HE DOESN'T SET THE
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          6   COMPANY-WIDE GOALS.
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          7             QUESTION:  MR. MARITZ YOU IDENTIFIED LAST WEEK AS
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          8   BEING A GROUP VICE-PRESIDENT; IS THAT CORRECT?
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          9             ANSWER:  UH-HUH.  SEVERAL TIMES.
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         10             QUESTION:  AND HE IS THE GROUP VICE-PRESIDENT WITH
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         11   RESPONSIBILITY FOR WINDOWS; IS THAT CORRECT?
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         12             ANSWER:  THAT'S AMONG HIS RESPONSIBILITIES.
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         13             QUESTION:  AND INCLUDED IN HIS RESPONSIBILITIES
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         14   WAS INTERNET EXPLORER; IS THAT CORRECT?
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         15             ANSWER:  OUR BROWSING TECHNOLOGY WAS PART OF THAT
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         16   GROUP.
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         17             QUESTION:  WAS INTERNET EXPLORER PART OF THAT
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         18   GROUP?
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         19             ANSWER:  YES.
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         20             QUESTION:  NOW, DID YOU EVER TELL MR. MARITZ THAT
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         21   BROWSER SHARE WAS NOT THE COMPANY'S NUMBER ONE GOAL?
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         22             ANSWER:  NO.
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         23             QUESTION:  YOU KNEW MR. MARITZ WAS TELLING PEOPLE
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         24   THAT BROWSER SHARE WAS THE COMPANY'S NUMBER ONE GOAL, DID
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         25   YOU NOT, SIR?
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          1             ANSWER:  I KNEW THAT MR. MARITZ WAS SAYING TO
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          2   PEOPLE THAT THE -- THAT A TOP GOAL AND PERHAPS NUMBER ONE
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          3   GOAL FOR HIS GROUP WAS BROWSER USAGE SHARE.
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          4             QUESTION:  INTERPRETING WHAT MR. MARITZ HAS
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          5   COMMUNICATED IN LIGHT OF THAT, DO YOU KNOW HOW MR. MARITZ
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          6   CAME TO THE VIEW THAT BROWSER SHARE WAS THE NUMBER ONE GOAL?
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          7             ANSWER:  WELL, I THINK HE WAS AWARE OF THE
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          8   INCREASING POPULARITY OF THE INTERNET AND THE GROWING USAGE
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          9   OF THE INTERNET AND FELT THAT ALL THE MANY, MANY INNOVATIONS
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         10   WE WERE DOING IN WINDOWS, THAT A PARTICULAR FOCUS HAD TO BE
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         11   DOING THE BEST JOB ON THE INTERNET AND INTERNET BROWSING
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         12   FEATURES OF THE OPERATING SYSTEM AND SEEING IF WE COULD
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         13   INNOVATE ENOUGH TO MAKE PEOPLE PREFER TO USE THAT TECHNOLOGY
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         14   FROM US.
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         15             QUESTION:  MR. GATES, ISN'T IT THE CASE THAT YOU
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         16   TOLD MR. MARITZ THAT BROWSER SHARE WAS A VERY, VERY
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         17   IMPORTANT GOAL AND THAT'S WHY HE BELIEVED IT?
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         18             ANSWER:  I GUESS NOW WE'RE DELVING INTO THE INNER
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         19   WORKINGS OF PAUL MARITZ'S MIND AND HOW HE COMES TO
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         20   CONCLUSIONS?
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         21             QUESTION:  WELL, LET ME TRY TO ASK YOU A QUESTION
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         22   THAT WON'T YOU REQUIRE TO DELVE INTO ANYBODY ELSE'S MIND.
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         23             DID YOU TELL MR. MARITZ THAT BROWSER SHARE WAS A
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         24   VERY, VERY IMPORTANT GOAL?
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         25             ANSWER:  I KNOW WE TALKED ABOUT BROWSER SHARE
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          1   BEING IMPORTANT.
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          2             QUESTION:  I'M NOT ASKING YOU WHAT HE SAID TO YOU.
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          3   I'M NOT ASKING YOU WHAT TOPIC YOU TALKED ABOUT.  I'M ASKING
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          4   YOU WHETHER YOU TOLD MR. MARITZ THAT BROWSER SHARE WAS A
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          5   VERY, VERY IMPORTANT GOAL?
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          6             ANSWER:  I REMEMBER THAT WE AGREED THAT IT WAS AN
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          7   IMPORTANT GOAL.  I'M NOT SURE WHICH ONE OF US REACHED THAT
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          8   FEELING BEFORE THE OTHER.
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          9             QUESTION:  DID YOU WRITE EXHIBIT 358, MR. GATES,
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         10   ON OR ABOUT JANUARY 5, 1996?
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         11             (END OF VIDEOTAPE EXCERPTS.)
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         12             MR. BOIES:  YOUR HONOR, DEPOSITION EXHIBIT 358 HAS
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         13   BEEN MARKED AS GOVERNMENT TRIAL EXHIBIT 295.
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         14             (VIDEOTAPE EXCERPT PLAYED AS FOLLOWS:)
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         15             ANSWER:  I DON'T REMEMBER DOING SO SPECIFICALLY,
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         16   BUT IT APPEARS THAT I DID.
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         17             QUESTION:  AND THE FIRST LINE OF THIS IS, "WINNING
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         18   INTERNET BROWSER SHARE IS A VERY, VERY IMPORTANT GOAL FOR
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         19   US."
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         20             DO YOU SEE THAT?
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         21             ANSWER:  I DO.
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         22             QUESTION:  DO YOU REMEMBER WRITING THAT, SIR?
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         23             ANSWER:  NOT SPECIFICALLY.
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         24             QUESTION:  NOW, WHEN YOU WERE REFERRING THERE TO
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         25   INTERNET BROWSER SHARE, WHAT WERE THE COMPANIES WHO WERE
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          1   INCLUDED IN THAT?
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          2             ANSWER:  THERE'S NO COMPANIES INCLUDED IN THAT.
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          3             QUESTION:  WELL, IF YOU'RE WINNING BROWSER SHARE,
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          4   THAT MUST MEAN THAT SOME OTHER COMPANY IS PRODUCING BROWSERS
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          5   AND YOU'RE COMPARING YOUR SHARE OF BROWSERS WITH SOMEBODY
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          6   ELSE'S SHARE OF BROWSERS; IS THAT NOT SO, SIR?
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          7             ANSWER:  YOU ASKED ME IF THERE ARE ANY COMPANIES
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          8   INCLUDED IN THAT AND NOW -- I'M VERY CONFUSED ABOUT WHAT
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          9   YOU'RE ASKING.
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         10             QUESTION:  ALL RIGHT, SIR, LET ME SEE IF I CAN TRY
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         11   TO CLARIFY.  YOU SAY HERE, "WINNING INTERNET BROWSER SHARE
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         12   IS A VERY, VERY IMPORTANT GOAL FOR US."  WHAT COMPANIES WERE
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         13   SUPPLYING BROWSERS WHOSE SHARE YOU WERE TALKING ABOUT?
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         14             ANSWER:  IT DOESN'T APPEAR THAT I'M TALKING ABOUT
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         15   ANY OTHER COMPANIES IN THAT SENTENCE.
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         16             QUESTION:  WELL, SIR, IS A MARKET SHARE SOMETHING
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         17   THAT IS COMPILED ONLY FOR ONE COMPANY?  I UNDERSTAND IF A
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         18   COMPANY HAS A MONOPOLY, THAT MAY BE SO, BUT IN A USUAL
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         19   SITUATION WHERE A COMPANY DOES NOT HAVE A MONOPOLY, A SHARE
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         20   ORDINARILY IMPLIES COMPARING HOW MUCH OF A PRODUCT ONE
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         21   COMPANY HAS WITH HOW MUCH OF A PRODUCT ANOTHER COMPANY HAS;
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         22   CORRECT?
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         23             ANSWER:  YES.
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         24             QUESTION:  NOW, WHEN YOU WERE TALKING ABOUT
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         25   INTERNET BROWSER SHARE HERE, WHAT COMPANIES WERE YOU TALKING
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          1   ABOUT?
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          2             ANSWER:  YOU'RE TRYING -- YOU SEEM TO BE
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          3   SUGGESTING THAT JUST BECAUSE SHARE INVOLVES COMPARING
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          4   MULTIPLE COMPANIES, THAT WHEN I WROTE THAT SENTENCE I WAS
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          5   TALKING ABOUT OTHER COMPANIES.  IT DOESN'T APPEAR TO ME THAT
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          6   I'M TALKING ABOUT OTHER COMPANIES IN THAT SENTENCE.  I'VE
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          7   REALLY READ IT VERY CAREFULLY AND I DON'T NOTICE ANY OTHER
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          8   COMPANIES IN THERE.
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          9             QUESTION:  OH, YOU MEAN YOU DON'T SEE ANY OTHER
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         10   COMPANY MENTIONED IN THAT SENTENCE; IS THAT WHAT YOU'RE
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         11   SAYING?
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         12             ANSWER:  THE SENTENCE DOESN'T APPEAR TO DIRECTLY
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         13   OR INDIRECTLY REFER TO ANY OTHER COMPANIES.
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         14             QUESTION:  WHEN YOU REFER TO AN INTERNET BROWSER
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         15   SHARE HERE, SIR, WHAT IS THE SHARE OF?
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         16             ANSWER:  BROWSER USAGE.
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         17             QUESTION:  OF COURSE, YOU DON'T SAY BROWSER USAGE
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         18   HERE, DO YOU SIR?
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         19             ANSWER:  NO, IT SAYS "SHARE."
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         20             QUESTION:  NOW, LET'S SAY THAT YOU MEANT BROWSER
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         21   USAGE BECAUSE THAT'S WHAT YOUR TESTIMONY IS.  WHAT BROWSER
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         22   USAGE WERE YOU TALKING ABOUT IN TERMS OF WHAT YOUR SHARE OF
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         23   BROWSER USAGE WAS?  WHAT BROWSERS?
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         24             ANSWER:  I'M NOT GETTING YOUR QUESTION.  ARE YOU
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         25   TRYING TO ASK WHAT I WAS THINKING WHEN I WROTE THIS
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                                                                              15
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          1   SENTENCE?
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          2             QUESTION:  LET ME BEGIN WITH THAT.  WHAT WERE YOU
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          3   THINK WHEN YOU WROTE THIS SENTENCE?
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          4             ANSWER:  I DON'T REMEMBER SPECIFICALLY WRITING
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          5   THIS SENTENCE.
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          6             QUESTION:  DOES THAT MEAN YOU CAN'T ANSWER WHAT
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          7   YOU WERE THINKING WHEN YOU WROTE THE SENTENCE?
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          8             ANSWER:  THAT'S CORRECT.
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          9             QUESTION:  OKAY.  SO SINCE THAT QUESTION IS THAT
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         10   YOU DON'T HAVE AN ANSWER TO -- YOU DON'T HAVE AN ANSWER TO
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         11   THAT QUESTION, LET ME PUT A DIFFERENT QUESTION.
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         12             ANSWER:  I HAVE AN ANSWER.  THE ANSWER IS I DON'T
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         13   REMEMBER.
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         14             QUESTION:  OKAY.  YOU DON'T REMEMBER WHAT YOU
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         15   MEANT.  NOW, LET ME TRY TO ASK YOU --
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         16             ANSWER:  I DON'T REMEMBER WHAT I WAS THINKING.
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         17             QUESTION:  IS THERE A DIFFERENCE BETWEEN
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         18   REMEMBERING WHAT YOU WERE THINKING AND REMEMBERING WHAT YOU
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         19   MEANT?
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         20             ANSWER:  IF THE QUESTION IS WHAT I MEANT WHEN I
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         21   WROTE IT, NO.
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         22             QUESTION:  OKAY.  SO YOU DON'T REMEMBER WHAT YOU
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         23   WERE THINKING WHEN YOU WROTE IT AND YOU DON'T REMEMBER WHAT
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         24   YOU MEANT WHEN YOU WROTE IT; IS THAT FAIR?
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         25             ANSWER:  AS WELL AS NOT REMEMBER WRITING IT.
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          1             QUESTION:  OKAY.  NOW, LET ME GO ON TO ANOTHER
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          2   PARAGRAPH AND SEE WHETHER YOU REMEMBER WRITING THAT OR NOT.
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          3   AND THAT IS THE SECOND PARAGRAPH, WHICH READS, "APPARENTLY A
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          4   LOT OF OEM'S ARE BUNDLING NON-MIRCOSOFT BROWSERS AND COMING
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          5   UP WITH OFFERINGS TOGETHER WITH INTERNET SERVICE PROVIDERS
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          6   THAT GET DISPLAYED ON THEIR MACHINES IN A FAR" -- AND YOU'VE
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          7   CAPITALIZED EACH OF THE LETTERS IN FAR -- "MORE PROMINENT
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          8   WAY THAN MSN OR OUR INTERNET BROWSER."
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          9             DO YOU SEE THAT?
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         10             ANSWER:  UH-HUH.
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         11             QUESTION:  DID YOU WRITE THAT SENTENCE, MR. GATES?
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         12             ANSWER:  I DON'T REMEMBER, BUT I HAVE NO REASON TO
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         13   DOUBT THAT I DID.
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         14             QUESTION:  DO YOU REMEMBER WHAT YOU WERE THINKING
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         15   WHEN YOU WROTE THAT SENTENCE OR WHAT YOU MEANT WHEN YOU
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         16   WROTE THAT SENTENCE?
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         17             ANSWER:  NO.
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         18             QUESTION:  DO YOU REMEMBER THAT IN JANUARY, 1996,
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         19   A LOT OF OEM'S WERE BUNDLING NON-MICROSOFT BROWSERS?
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         20             ANSWER:  I'M NOT SURE.
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         21             QUESTION:  WHAT WERE THE NON-MIRCOSOFT BROWSERS
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         22   THAT YOU WERE CONCERNED ABOUT IN JANUARY OF 1996?
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         23             ANSWER:  WHAT'S THE QUESTION?  YOU'RE TRYING TO
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         24   GET ME TO RECALL WHAT OTHER BROWSERS I WAS THINKING ABOUT
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         25   WHEN I WROTE THAT SENTENCE?
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          1             QUESTION:  NO, BECAUSE YOU'VE TOLD ME THAT YOU
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          2   DON'T KNOW WHAT YOU WERE THINKING ABOUT WHEN YOU WROTE THAT
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          3   SENTENCE.
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          4             ANSWER:  RIGHT.
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          5             QUESTION:  WHAT I'M TRYING TO DO IS GET YOU TO
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          6   TELL ME WHAT NON-MIRCOSOFT BROWSERS YOU WERE CONCERNED ABOUT
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          7   IN JANUARY OF 1996.
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          8             ANSWER:  IF IT HAD BEEN ONLY ONE, I PROBABLY WOULD
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          9   HAVE USED THE NAME OF IT.  INSTEAD, I SEEM TO BE USING THE
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         10   TERM NON-MIRCOSOFT BROWSERS.
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         11             QUESTION:  MY QUESTION IS WHAT NON-MIRCOSOFT
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         12   BROWSERS WERE YOU CONCERNED ABOUT IN JANUARY OF 1996?
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         13             ANSWER:  I'M SURE -- WHAT'S THE QUESTION?  IS
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         14   IT -- ARE YOU ASKING ME ABOUT WHEN I WROTE THIS E-MAIL OR
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         15   WHAT ARE YOU ASKING ME ABOUT?
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         16             QUESTION:  I'M ASKING YOU ABOUT JANUARY OF 1996.
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         17             ANSWER:  THAT MONTH?
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         18             QUESTION:  YES, SIR.
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         19             ANSWER:  AND WHAT ABOUT IT?
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         20             QUESTION:  WHAT NON-MIRCOSOFT BROWSERS WERE YOU
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         21   CONCERNED ABOUT IN JANUARY OF 1996?
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         22             ANSWER:  I DON'T KNOW WHAT YOU MEAN "CONCERNED."
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         23             QUESTION:  WHAT IS IT ABOUT THE WORD "CONCERNED"
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         24   THAT YOU DON'T UNDERSTAND?
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         25             ANSWER:  I'M NOT SURE WHAT YOU MEAN BY IT.
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          1             QUESTION:  IS --
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          2             ANSWER:  IS THERE A DOCUMENT WHERE I USE THAT
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          3   TERM?
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          4             QUESTION:  IS THE TERM "CONCERNED" A TERM THAT
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          5   YOU'RE FAMILIAR WITH IN THE ENGLISH LANGUAGE?
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          6             ANSWER:  YES.
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          7             QUESTION:  DOES IT HAVE A MEANING THAT YOU'RE
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          8   FAMILIAR WITH?
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          9             ANSWER:  YES.
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         10             QUESTION:  USING THE WORD "CONCERNED" CONSISTENT
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         11   WITH THE NORMAL MEANING THAT IT HAS IN THE ENGLISH LANGUAGE,
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         12   WHAT MICROSOFT -- OR WHAT NON-MIRCOSOFT BROWSERS WERE YOU
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         13   CONCERNED ABOUT IN JANUARY OF 1996?
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         14             ANSWER:  WELL, I THINK I WOULD HAVE BEEN CONCERNED
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         15   ABOUT INTERNET EXPLORER, WHAT WAS GOING ON WITH IT.  WE
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         16   WOULD HAVE BEEN LOOKING AT OTHER BROWSERS THAT WERE IN USE
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         17   AT THE TIME.  CERTAINLY NAVIGATOR WAS ONE OF THOSE.  AND I
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         18   DON'T KNOW WHICH BROWSER AOL WAS USING AT THE TIME, BUT IT
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         19   WAS ANOTHER BROWSER.
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         20             QUESTION:  WHAT I'M ASKING, MR. GATES, IS WHAT
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         21   OTHER BROWSERS OR WHAT NON-MIRCOSOFT BROWSERS WERE YOU
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         22   CONCERNED ABOUT IN JANUARY OF 1996?  I'M NOT ASKING YOU WHAT
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         23   YOU WERE LOOKING AT, ALTHOUGH THAT MAY BE PART OF THE
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         24   ANSWER, AND I DON'T MEAN TO EXCLUDE IT, BUT WHAT
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         25   NON-MIRCOSOFT BROWSERS WERE YOU CONCERNED ABOUT IN JANUARY
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                                                                              19
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          1   OF 1996?
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          2             ANSWER:  WELL, OUR CONCERN WAS TO PROVIDE THE BEST
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          3   INTERNET SUPPORT, AMONG OTHER THINGS, IN WINDOWS.  AND IN
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          4   DEALING WITH THAT CONCERN, I'M SURE WE LOOKED AT COMPETITIVE
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          5   PRODUCTS, INCLUDING THE ONES I MENTIONED.
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          6             QUESTION:  LET ME TRY TO USE YOUR WORDS AND SEE IF
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          7   WE CAN MOVE THIS ALONG.  WHAT COMPETITIVE PRODUCTS DID YOU
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          8   LOOK AT IN JANUARY OF 1996 IN TERMS OF BROWSERS?
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          9             ANSWER:  I DON'T REMEMBER LOOKING AT ANY SPECIFIC
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         10   PRODUCTS DURING THAT MONTH.
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         11             QUESTION:  WERE THERE SPECIFIC COMPETITIVE
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         12   PRODUCTS THAT IN JANUARY OF 1996 YOU WANTED TO INCREASE
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         13   MICROSOFT'S SHARE WITH RESPECT TO THOSE PRODUCTS?
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         14             MR. HEINER:  OBJECTION.
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         15             QUESTION:  DO YOU UNDERSTAND THE QUESTION,
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         16   MR. GATES?
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         17             ANSWER:  I'M PAUSING TO SEE IF I CAN UNDERSTAND
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         18   IT.
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         19             QUESTION:  IF YOU DON'T UNDERSTAND IT, I'D BE
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         20   HAPPY TO REPHRASE IT.
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         21             ANSWER:  GO AHEAD AND REPHRASE IT.  I PROBABLY
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         22   COULD HAVE UNDERSTOOD IT IF I THOUGHT ABOUT IT, BUT GO
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         23   AHEAD.
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         24             QUESTION:  OKAY.  IN JANUARY, 1996, YOU WERE AWARE
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         25   THAT THERE WERE NON-MIRCOSOFT BROWSERS THAT WERE BEING
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          1   MARKETED; IS THAT CORRECT?
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          2             ANSWER:  I CAN'T REALLY CONFINE IT TO THAT MONTH,
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          3   BUT I'M SURE IN THAT TIME PERIOD I WAS AWARE OF OTHER
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          4   BROWSERS BEING OUT.
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          5             QUESTION:  AND WERE THOSE NON-MIRCOSOFT BROWSERS,
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          6   OR AT LEAST SOME OF THEM, BEING MARKETED IN COMPETITION WITH
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          7   MICROSOFT'S BROWSER?
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          8             ANSWER:  USERS WERE MAKING CHOICES ABOUT WHICH
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          9   BROWSER TO SELECT.
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         10             QUESTION:  IS THE TERM "COMPETITION" A TERM THAT
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         11   YOU'RE FAMILIAR WITH, MR. GATES?
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         12             ANSWER:  YES.
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         13             QUESTION:  AND DOES IT HAVE A MEANING IN THE
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         14   ENGLISH LANGUAGE THAT YOU'RE FAMILIAR WITH?
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         15             ANSWER:  ANY LACK OF UNDERSTANDING OF THE QUESTION
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         16   DOESN'T STEM FROM THE USE OF THAT WORD.
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         17             QUESTION:  OKAY.  AND YOU UNDERSTAND WHAT IS MEANT
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         18   BY NON-MIRCOSOFT BROWSERS, DO YOU NOT, SIR?
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         19             ANSWER:  NO.
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         20             QUESTION:  YOU DON'T?  IS THAT WHAT YOU'RE TELLING
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         21   ME?  YOU DON'T UNDERSTAND WHAT THAT MEANS?
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         22             ANSWER:  YOU'LL HAVE TO BE MORE SPECIFIC.  WHAT --
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         23             QUESTION:  DO YOU UNDERSTAND WHAT IS MEANT BY
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         24   NON-MIRCOSOFT BROWSERS?
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         25             ANSWER:  IN THE RIGHT CONTEXT, I'D UNDERSTAND
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--- End of deposition transcript excerpt ---