Intel denies AMD allegations of "first-dollar" rebate system
AMD's initial filing detailed a system of rebates, quotas, and customer "loyalty" programs that, according to the complaint:

have the practical and intended effect of creating exclusive or near-exclusive dealing arrangements; threats of economic retaliation against those who give, or even contemplate giving, too much of their business to AMD, or who refuse to limit their AMD business to Intel-approved models, brands, lines and/or sectors, or who cooperate too closely with AMD's promotion of its competitive processors; and misuse of industry standards-setting processes so as to disadvantage AMD products in the marketplace.

AMD spends the bulk of its complaint detailing the function of these rebate systems, and explaining how they are allegedly used to tie the hands of OEMs, distributors, and retailers. It's worth noting that this is the type of behavior the JFTC recommended Intel cease.

Note, also, that MSS (as referenced in the quote below) is a ratio that measures what percentage of an OEM's total shipments include Intel processors.

From the JFTC decision:

IJKK [Intel Japan], since May 2002, has made the five major Japanese OEMs refrain from adopting competitors' CPUs for all or most of the PCs manufactured and sold by them or all of the PCs that belong to specific groups of PCs referred to as 'series', by making commitments to provide the five OEMs with rebates and/or certain funds referred to as 'MDF' (Market Development Fund) in order to maximize their MSS, respectively, on condition that

(a) the Japanese OEMs make MSS at 100% and refrain from adopting competitors' CPUs.

(b) the Japanese OEMs make MSS at 90%, and put the ratio of competitors' CPUs in the volume of CPUs to be incorporated into the PCs manufactured and sold by them down to 10%; or

(c) the Japanese OEMs refrain from adopting competitors' CPUs to be incorporated into PCs in more than one series with comparatively large amount of production volume to others.

Intel, as we've discussed, disputes the JFTC's findings of fact, and was not required to accept them in order to accept the recommendation. Intel's response to AMD's allegations regarding their rebate system is simple and direct:

Intel further states that it offers certain discounts and other financial incentives that reduce the price of microprocessors to meet competition from AMD and to expand the demand for Intel microprocessors and the products containing those microprocessors. Intel further states that AMD seeks to stifle Intel's ability to meet competition and compete on the merits through lower pricing.

Given the difficulty of proving customers have been harmed by Intel's pricing or rate of product introduction, the question of whether or not Intel has used its marketing power to bar OEMs from stocking AMD parts will be an essential component of any AMD antitrust claim. Intel, as noted above, simply and flatly denies that it exercises its market power any differently than any number of other firms—including AMD.

Intel's response to specific quotations
AMD's filing contains a number of attributed statements that harshly condemn (or strongly indicate) Intel's anti-competitive behavior. These include:

According to Gateway executives, their Company has paid a high price for even its limited AMD dealings. They claim that Intel has beaten them into "guacamole" in retaliation.

And:

In return for . . . exclusivity, according to IBM executive Ed Thum, Intel paid IBM "millions of dollars in market development funds."

The fact that company executives were willing to provide (or have not protested) such direct quotations in AMD's initial filing was generally seen as additional weight for AMD's story.

Intel's answer to such quotations is repeated throughout their filing, and represented in the following quotation:

Intel lacks information or belief regarding the nature of AMD's negotiations with IBM to admit or deny these allegations, and on that basis denies them. Intel lacks information or belief to admit or deny any statement or representation of state of mind attributed by AMD to a third party and on that basis denies them. Intel further denies the conduct attributed to it by any purported third-party statement alleged in paragraph 51.

AMD will have to prove, in a court of law, that "Gateway executives" or Ed Thum both made the statements that they are alleged to have made, and that those statements fairly and factually represented an actual state of events. Intel, for its part, denies them in the language above.

The only exceptions are the allegations in AMD's original complaint, attributing certain comments to the President of Acer, Stan Shi. Intel's brief mentions these allegations specifically, and alleges that "Acer's Chairman and CEO, Stan Shi, has publicly stated that his conversation with Mr. Barrett, contrary to AMD's allegations, focused entirely on industry development and technology trends."

Alleged compiler optimizations
From Intel's response:

Intel denies that its compilers are programmed to cause AMD microprocessors to crash. It further states that its compilers do not use the CPUID instruction to generate a code path that is specifically reserved for AMD processors.

This is nothing less than a direct refutation of AMD's claims regarding Intel compiler performance and operation, as quoted below:

Intel has designed its compiler purposely to degrade performance when a program is run on an AMD platform . . . . If the program detects a "Genuine Intel" microprocessor, it executes a fully optimized code path and operates with the maximum efficiency. However, if the program detects an "Authentic AMD" microprocessor, it executes a different code path that will degrade the program's performance or cause it to crash.

The compiler optimization issue, while both interesting and integral to CPU performance measurements, has always seemed a bit off-topic when compared to the body of AMD's initial filing. I'll be curious to see if this point of contention is preserved as the case moves towards trial, or is ultimately dropped by the wayside.