The audits began at the top of the organization chart and fanned out through the company. If any irregularities were found, the legal department investigated the source, imposed a remedy and updated its training to prevent similar problems from emerging again.
The most powerful weapon in the legal team's arsenal was the mock deposition. Following a raid on a senior executive and his unit, Dunlap would then hire an antitrust litigator to cross-examine the manager in front of the entire executive staff, using confiscated materials to fuel the legal attack.
After an hour of intensive questioning, the outside attorney would spend additional time discussing key lessons and answering questions from the often shaken audience.
"It's fascinating to see," Grove says. "A memo is introduced into evidence and you shrug. You fully understand how that memo could be written. Moreover, you could have written it yourself. And then you see that memo turned into a tool and a weapon against you, in front of your eyes."
Despite Grove and Dunlap's best efforts, Intel has not been entirely immune to investigation. The EU Commission recently initiated an investigation; and the FTC looked into Intel's activities twice in the 1990s, closing each review without further action.
With the exception of a narrow consent decree signed in 1999 regarding how Intel uses its intellectual property, the company has avoided the long legal entanglements that have plagued other powerful companies.
"Since antitrust is embedded in everything we do," Grove says, "we can control our destiny."
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