(IE) to sales of Windows 98, making IE difficult to remove from Windows 98 (e.g., not putting it on the "Remove Programs" list), and designing Windows 98 to work "unpleasantly" with Netscape Navigator constituted an illegal tying of Windows 98 and IE. Microsoft's counterargument was that a web browser and a mail reader are simply part of an operating system, included with other personal computer operating systems, and the integration of the products was technologically justified. Just as the definition of a car has changed to include things that used to be separate products, such as speedometers and radios, Microsoft claimed the definition of an operating system has changed to include their formerly separate products. The United States Court of Appeals for the District of Columbia Circuit rejected Microsoft's claim that Internet Explorer was simply one facet of its operating system, but the court held that the tie between Windows and Internet Explorer should be analyzed deferentially under the Rule of Reason. The U.S. government claim settled before reaching final resolution. As to the tying of Office, parallel cases against Microsoft brought by State Attorneys General included a claim for harm in the market for office productivity applications. The Attorneys General abandoned this claim when filing an amended complaint. The claim was revived by Novell where they alleged that manufacturers of computers ("OEMs") were charged less for their Windows bulk purchases if they agreed to bundle Office with every PC sold than if they gave computer purchasers the choice whether or not to buy Office along with their machines — making their computer prices less competitive in the market. The Novell litigation has since settled. Microsoft has also tied its software to the third-party Android mobile operating system, by requiring manufacturers that license patents it claims covers the OS and smartphones to ship Microsoft Office Mobile and Skype applications on the devices. Anti-tying provision of the Bank Holding Company Act In 1970, Congress enacted section 106 of the Bank Holding Company Act Amendments of 1970 (BHCA), the anti-tying provision, which is codified at 12 U.S.C. § 1972. The statute was designed to prevent banks, whether large or small, state or federal, from imposing anticompetitive conditions on their customers. Tying is an antitrust violation, but the Sherman and Clayton Acts did not adequately protect borrowers from being required to accept conditions to loans issued by banks, and section 106 was specifically