The software of an operating system (hereafter referred to as OS) is substantially different from concrete products. In that software is not tangible, it is difficult, at best, to determine the number of “products” on the basis of appearance when there are several application software products installed in one OS. That is, for example, we are hard pressed when it comes to counting the exact number of “products” when both “Microsoft Word” and “Microsoft PowerPoint” are installed in one Windows OS. Under the American Antitrust Law, an illegal tying arrangement is sustained when at least two products are bound together for sale as one unit. Thus, when an application software product is installed in an OS, the crucial issue is how to determine whether the OS should be regarded as two separate software products, or as only one OS product that contains the functions of the application software. In other words, carrying other application software functions as a platform, particular1y in view of their intangibility, makes it difficu1t to clear1y define whether it is one or two products once the OS has been integrated with other application software functions. Understandably, this has fundamentally challenged the way the Antitrust Law defines a “tying arrangement”. On May 18, 1998, the United Sates Department of Justice and dozens of state attorney-generals filed an antitrust suit against Microsoft Corporation. The most contentious issue was the very question as to how to determine whether they should be regarded as two separate software products or only as one when Microsoft proceeded with its contractual and technological bundling of the IE web browser with its Windows operating system. This paper explores the circumstances under which the manufacturer of an OS may be in violation of a tying arrangement under the Antitrust Law. Taking into consideration the U.S. Supreme Court’s precedent and comparing the viewpoints of the district court and the appeal court toward the Microsoft case, we seek appropriate criteria so as to be in a better position to determine whether the integration of an OS with application software should be regarded as two separate software products, or as only one OS product which contains the function of the application software.