The company declined to make representatives from the subsidiaries available, saying that all SAM-related questions should be directed to Rivera.

Discussions of compensation and quotas don't sit well with Milton Bliss, CIO at Sunwest Management Inc. in Salem, Ore., especially after listening to Microsoft insist that a SAM engagement's purpose is neither sales nor an audit.

"I cannot possibly understand how Microsoft could argue that it's not an audit, when they are commissioning the people performing the work based upon how much money they bring in," Bliss said.

"I am annoyed by their dancing around the words."

Rivera said he recognizes that many customers feel threatened when the SAM team approaches them. But, he added, the SAM approach was designed to be a "middle point" on the pendulum swing between doing "absolutely nothing" to ensure that companies are properly licensed to "beating customers over the head with a hammer" by doing formal audits. Rivera said his title changed from director of worldwide license compliance to head of the SAM program when it was launched in the U.S. a year ago, reflecting the company's changed approach.