with various OLSs, ICPs, ISVs, Compaq and Apple into question. They were alleged as exclusive dealing arrangements because each of these agreements with Microsoft required the other party to promote and distribute Internet Explorer and to exclude Navigator. In exchange, Microsoft offered promotional patronage, substantial financial subsidies, technical support, and other valuable consideration. Violation occurs when the practice is to place so much of a market's available distribution outlets in the hands of a single firm as to make it difficult for other firms to continue to compete effectively, or even to exist, in the relevant market. Precedent set in Standard Oil Co. VS United States defined distribution outlets in the hands of a single firm holding 40% or more of distribution outlets in the relevant market. Because the case law suggested that, unless the evidence demonstrated that Microsoft's agreements excluded Netscape altogether from access to roughly 40% of the browser market, exclusive dealing had not taken place. The Court found no violation to this aspect of Section One. The findings of the Supreme Court asserted the claims of the plaintiff states. The same facts that established liability under Sections One and Two of the Sherman Act mandated a finding of liability under provisions in each states own laws. Microsoft contended that a plaintiff cannot succeed in an antitrust claim under the laws of California, Louisiana, Maryland, New York, Ohio, or Wisconsin without proving a variable that is not required under the Sherman Act, namely, intrastate impact. Assuming that each of those states has limited the application of its antitrust laws to activity that has a significant, adverse effect on competition in the state or is counter to state interests, than the facts presented at trail showed Microsoft to be culpable. The Court found that certain companies had been adversely affected by Microsoft's anti-competitive camp...
