Microsoft attorneys tried to get the expert, Andrew Schulman, to say he'd since changed his mind about one aspect of his opinion in a recent deposition, but as you can see on page 36 of the February 6, 2007 deposition [PDF], that is not the case. The question and answer went like this:

Q. Well, now that you appreciate what the Competitive Impact Statement says and what the government of the United States told a federal judge about the meaning of the final judgment, do you want to withdraw the opinion that you've offered that even after the final judgment in the United States v. Microsoft, a large number of APIs used by Microsoft Middleware remain undocumented?

A. No.

One of the allegations is that in this expert's opinion, Andrew Schulman, “Microsoft Office uses (and copies) undocumented DirectUI APIs” and “Microsoft Office and other Microsoft applications use undocumented Windows Line Services APIs”. As you all know, I'm not a programmer myself, so I'll toss the ball to all of you who are and ask you this: might that give us a clue about why it seems so hard to make ODF and OpenXML 100% interoperable? If so, would anyone but Microsoft ever be able to really render Microsoft Office documents perfectly, if only Microsoft knows the hidden bits? If that is correct, then how could that be a standard?

Here are the headings from the Supplemental Expert Report:

1. The source code for Windows XP and Microsoft Office provide additional bases for opinion #21 in my June 2, 2006 technical expert report (“Microsoft Office uses (and copies) undocumented DirectUI APIs”).

2. The source code for Windows XP and Microsoft Office provide additional bases for opinion #20 in my earlier report (“Microsoft Office and other Microsoft applications use undocumented Windows Line Services APIs”).

3. The source code for Windows XP and IE7Beta3 provide additional bases for opinion #36 in my earlier report (“IE7 and MSN Messenger use the undocumented DirectUser (DUser, Direct UI) API”).

4. The source code for Windows XP and Internet Explorer provide additional bases for opinion #35 in my earlier report (“Internet Explorer uses Microsoft’s undocumented Line Services API”).

5. The source code for Windows XP and Internet Explorer provide additional bases for opinion #34 in my earlier report (“Even after the final judgment in United States v. Microsoft, a large number of APIs used by Microsoft middleware remain undocumented”).

6. Microsoft’s application and middleware users of undocumented Windows APIs are not “trusted components”

7. Microsoft’s source code provides additional bases for opinion #28 in my earlier report (“Undocumented Windows interfaces used by Microsoft applications and middleware really are APIs”).

8. Microsoft’s source code provides additional bases for opinion #38 in my earlier report (“Microsoft application and middleware access to Microsoft Windows source code is a substantial advantage that was not available to ISVs”).

9. Examining MCPP and WSPP documentation

10. OS/2-Related Warning Message in Combined DOS/Windows Install from 1991-1992, and in Later Microsoft Products

11. Dell Recovery CD Contains MS-DOS 7.1 from Windows 98 SE

12. Several then-undocumented APIs cited in my earlier report have recently been documented

13. Tests using ToolHelp and Dependency Walker provides additional support for opinion # 8 in my earlier report (“Windows is ‘componentizable,’ not monolithic, and Microsoft knows how to split Windows into smaller pieces”).

Each subheading includes examples. This is more up your alley than mine, so enjoy. This is all followed by a list of materials considered, and the final one on the list, my sense of humor couldn't help but notice, not that it means anything to the world at large, is a SCO website. Small world.

Here, finally, are all the other documents now made available by plaintiffs in the case, what they call the Andrew Schulman materials:

Deposition Exhibit 16 (Federal Register of November 28, 2001, with the DOJ-MS Final Judgment, as downloaded from www.access.gpo.gov)
Deposition Exhibit 17 [Part A; Part B, PDFs] (Response of the United States to Public Comments on the Revised Proposed Final Judgment, dated February 2002.)
Deposition Exhibit 18 (handwritten notes of Andrew Schulman)