Alvarado also named 100 "John Doe" co-defendants. "[They] are the persons, firms and corporations who have participated with Microsoft in the wrongdoings complained of and performed acts and made statements in furtherance thereof," the lawsuit read. "The Doe Defendants acts as co-conspirators and aided and abetted, or participated with, Microsoft in the commission of wrongful acts."

Bowermaster claimed that Microsoft had no downgrade program as such. "Microsoft does not have a downgrade program. It does offer downgrade rights as part of some Windows Vista licenses, including Windows Vista Business purchased through the OEM channel." That, however, belies the fact that Microsoft has regularly offered downgrade rights to users. When it released Windows XP in 2001, it allowed people who had XP licenses to , according to Gartner analyst Michael Silver.

Alvarado is seeking compensatory damages and wants the case declared a class-action suit.