of efficiency justifications. Apple products The tying of Apple products is an example of commercial tying that has caused recent controversy. When Apple initially released the iPhone on June 29, 2007, it was sold exclusively with AT&T (formerly Cingular) contracts in the United States. To enforce this exclusivity, Apple employed a type of software lock that ensured the phone would not work on any network besides AT&T's. Related to the concept of bricking, any user who tried to unlock or otherwise tamper with the locking software ran the risk of rendering their iPhone permanently inoperable. This caused complaints among many consumers, as they were forced to pay an additional early termination fee of $175 if they wanted to unlock the device safely for use on a different carrier. Other companies such as Google complained that tying encourages a more closed-access-based wireless service. Many questioned the legality of the arrangement, and in October 2007 a class-action lawsuit was filed against Apple, claiming that its exclusive agreement with AT&T violates California antitrust law. The suit was filed by the Law Office of Damian R. Fernandez on behalf of California resident Timothy P. Smith, and ultimately sought to have an injunction issued against Apple to prevent it from selling iPhones with any kind of software lock. In July 2010, federal regulators clarified the issue when they determined it was lawful to unlock (or in other terms, "jail break") the iPhone, declaring that there was no basis for copyright law to assist Apple in protecting its restrictive business model. Jail breaking is removing operating system or hardware restrictions imposed on an iPhone (or other device). If done successfully, this allows one to run any application on the phone they choose, including applications not authorized by Apple. Apple told regulators that modifying the iPhone operating system leads to the creation of an infringing derivative work that is protected by copyright law. This means that the license on the operating system forbids software modification. However, regulators agreed that modifying an iPhone's firmware/operating system to enable it to run an application that Apple has not approved fits comfortably within the four corners of fair use. Microsoft products Another prominent case involving a tying claim was United States v. Microsoft. By some accounts, Microsoft ties together Microsoft Windows, Internet Explorer, Windows Media Player, Outlook Express and Microsoft Office. The United States claimed that the bundling of Internet Explorer