Winter 2001: Volume 18, Number 1

 

 

J. Gregory Sidak

An Antitrust Rule for Software Integration

 

What is the proper legal standard for product integration involving software? Because software is subject to low marginal costs, network effects, and rapid technological innovation, the Supreme Court’s existing antitrust rules on tying arrangements, which evolved from industries not possessing such characteristics, are inappropriate. In this Article, I ask why firms integrate software products. Next, I review the Supreme Court’s tying decisions in Jefferson Parish and Eastman Kodak. I propose an approach to judging the lawfulness of product integration in technologically dynamic markets that supplements the Supreme Court’s current standard with four additional steps in cases of tying of computer software. Thereafter, I examine the D.C. Circuit’s approach to software integration, which arose from that court’s 1998 interpretation, in Microsoft II, of an antitrust consent decree between the U.S. Department of Justice and Microsoft Corporation. I argue that the D.C. Circuit’s rule has general applicability and should be recognized as the appropriate standard for software integration under antitrust law. I show how my approach imparts greater clarity to the D.C. Circuit’s rule. I examine the competing product integration rule proposed in 2000 by Professor Lawrence Lessig as amicus curiae in the government’s subsequent antitrust case against Microsoft, concerning the integration of Internet Explorer and Windows 98. My approach enables Professor Lessig’s analysis to be reconciled with the D.C. Circuit’s rule, but Professor Lessig’s rule, on its own, would contain serious shortcomings. Thereafter, I evaluate Judge Thomas Penfield Jackson’s April 2000 findings of law on the integration of Internet Explorer and Windows 98. I conclude that Judge Jackson’s approach, in contrast to the D.C. Circuit’s rule as refined by my approach, would harm consumers in the technologically dynamic market for computer software.

 

 

Jeffrey M. Gaba

Regulation by Bootstrap: Contingent Management of Hazardous Wastes Under the Resource Conservation and Recovery Act

 

In the last few years, EPA has increasingly employed the questionable technique of “contingent management” to regulate wastes under the federal Resource Conservation and Recovery Act (RCRA) in order to limit the costs and avoid the stigma of hazardous waste classification. Through the technique of contingent management, EPA has exempted materials from classification as hazardous waste on the condition that the materials are managed in the particular manner specified in the regulation. The ultimate bootstrap, contingent management allows EPA to regulate non-hazardous wastes over which it has no statutory jurisdiction. Perhaps more troubling, contingent management allows EPA to avoid the specific statutory scheme adopted by Congress for the regulation of hazardous wastes.

         Although one case appears to endorse the use of contingent management, the most significant issues raised by this technique have not been addressed. The legality of the contingent management technique is far from clear. Among other things, EPA is relying on the factors of cost and stigma that may not properly be considered in classifying wastes as hazardous, and EPA is avoiding specific statutory requirements that would otherwise apply to hazardous wastes. Furthermore, the rationale used by EPA to justify contingent management is essentially boundless; EPA could potentially eliminate the statutory requirements of RCRA by regulating any otherwise hazardous waste through contingent management. EPA is, in effect, asserting discretion to regulate such wastes in any manner it deems appropriate. This is a position rejected by Congress when it amended RCRA in 1984 to constrain EPA’s discretion. Given these concerns, courts should closely scrutinize EPA’s use of contingent management and not defer to EPA’s construction of its authority under RCRA.

        After discussing the rationale and weaknesses of contingent management, this Article concludes with recommendations for a more rational and consistent means of classifying and regulating hazardous waste.

 

 

Jerry A. Hausman, J. Gregory Sidak, and Hal J. Singer

Residential Demand for Broadband Telecommunications and Consumer Access to Unaffiliated Internet Content Providers

 

In this article, we examine the open access debate in the context of cable services and broadband Internet services from an antitrust framework.  Our analysis is prompted by the recent AT&T-MediaOne and AOL-Time Warner mergers, which raise issues concerning the impact of integrated cable content and Internet access to residential telecommunications.  Economic analysis, demographic surveys and federal antitrust guidelines each indicate that the broadband Internet access market is distinct from the narrowband Internet access market. Emerging or competing technologies, such as satellite Internet services or digital subscriber lines, cannot discipline the broadband Internet access market over the relevant time horizons.  Vertical integration increases the incentives and power of cable providers to discriminate against unaffiliated broadband content, thereby substantially decreasing consumer welfare.  We conclude that the recent mergers of cable content and Internet access is the most current manifestation of the classic strategy of cable providers to control alternate channels of content distribution.