In addition to presiding over the states request for tougher remedies, Kollar-Kotelly is separately reviewing the federal settlement proposal, which was crafted last year by Microsoft and the DOJ. The settlement was reached after the U.S. Court of Appeals for the District of Columbia Circuit upheld District Judge Thomas Penfield Jacksons ruling that Microsoft illegally maintained a monopoly in PC operating systems. However, the appeals court rejected Jacksons order to split Microsoft in two (and removed Jackson from the case) and instead directed Kollar-Kotelly to determine behavioral remedies for the illegal conduct.