In this motion, Microsoft claims that a Special Master is unnecessary in this case, and that Lawrence Lessig in particular is biased towards Microsoft.  Microsoft supports this claim with the following three points:

• No exceptional condition requires a Special Master.  In order for a court to appoint a Special Master to a case, the Court must demonstrate that exceptional conditions require it.  The term "exceptional condition" is narrowly defined and does not include court congestion, unusual complexity of the case, or the unusualy long length of time for the case.  Microsoft suggests that the technical complexities of the case warrant a technical expert, but not a Special Master.
• The Order of Reference to the Special Master give him powers which should only be exercised by the Court, such as the power to resolve fundamental factual disputes and to apply legal standards.
• Microsoft was given no notice of the appointment of the Special Master nor were they given a chance to object to the choice.  Typically, both parties are allowed to nominate candidates for the position of Special Master, or at least object to the suggested candidate.  Microsoft claims that it objects to the appointment of Lawrence Lessige as Special Master on the basis that he is biased against Microsoft.

 Actual Text of Microsoft's Motion to Revoke the Special Master

In addition to petitioning the Court to revoke the Special Master, Microsoft appealed to Lawrence Lessig himself, asking him to step down from his position. In this letter, Microsoft confronts Lessig with evidence that it feels proves his bias: three electronic mail messages to Netscape in which he expresses anti-Microsoft sentiment.

 Microsoft's letter to Lessig
 E-mail exchange between Lessig and Netscape