“At points, Kollar-Kotelly chastised Microsoft with some fairly harsh language. The judge said one argument”borders on the frivolous,” while calling another “improper.” At another point, she said one Microsoft claim was “flatly contradicted” by the initial antitrust ruling handed down by U.S. District Judge Thomas Penfield Jackson.
From a legal perspective, the stiffest admonishment may have come on page 28 of the memorandum, where Kollar-Kotelly accused Microsoft of "mischaracterizing their holdings."”