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Trip Report: Nader's conference on Microsoft
- To: Multiple recipients of list <am-info@essential.org>
- Subject: Trip Report: Nader's conference on Microsoft
- From: Cem Kaner <kaner@kaner.com>
- Date: Mon, 01 Dec 1997 22:49:51 -0800
I posted this report to a software developers' list that I subscribe to,
but realized that some of you might also be interested in it. Hope you
enjoy it.
==============================================
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.
========== Economics ==========
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/.
----------------
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.
================ The Threat =================
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.
=========== The Lawsuits ==========
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’s view,
Microsoft should be forced to sit on its hands while
competitors attempt to take away one of the most important
aspects of Microsoft’s 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. ¶15. 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. ¶ 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.
========= Remedies ==========
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.
==================================
Well, that's the end of my report. I hope that you found it interesting
and/or useful.
-- Cem Kaner
----------------------------------------------------------------------
Cem Kaner, J.D., Ph.D. Attorney at Law
PO Box 1200, Santa Clara, CA 95052 kaner@kaner.com
Please read my book, "Testing Computer Software" Thomson Press.
This communication is not legal advice or a legal opinion.This message
does not create an attorney-client relationship between you and me.
Please do not act on any law-related information in this message
without seeking the advice of your attorney.
----------------------------------------------------------------------
_______________________________________________________________________
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.
_______________________________________________________________________
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.