power in a relevant market, a demonstration that the defendant used anti-competitive methods to achieve or maintain its position has to exist. Prior cases, such as Aspen Skiing Co. VS Aspen Highlands Skiing Corp, have established an analytical approach to determining whether the challenged business practices are anti-competitive in the context of a monopoly maintenance claim. The primary question in regard to Microsoft is whether its conduct is "exclusionary." It has to be determined that Microsoft significantly restricted or threatened to restrict the ability of other firms to compete in the relevant market, based on the merits of what they have offer customers. Microsoft business practices were found by the Court to be predatory, meaning that Microsoft made a conscious effort to build or maintain barriers to keep competition at bay. The Court determined that Microsoft recognized early on that middleware technology, namely, Netscape's Navigator Web browser and SunMicros implementation of the Java technology, was a Trojan horse. Microsoft feared that once having infiltrated the applications barrier, middleware would give rival operating systems the ability to enter the market for Intel-compatible PC operating systems unimpeded. Alerted to the threat, Microsoft strove, according to the Finding of Fact, over a period of approximately four years to prevent middleware technologies from fostering the development of enough full-featured, cross-platform applications to erode the applications barrier. In pursuit of this goal, Microsoft sought to convince developers to concentrate on Windows-specific APIs and ignore interfaces exposed by the two incarnations of middleware that posed the greatest threat. The Court found that Microsoft's campaign succeeded in preventing by several years, and perhaps permanently, Navigator and Java from reaching their potential to open the market for Intel-compatible PC operating systems to competition, base...
