The year 1998 was significant in Microsoft's history, with Bill Gates appointing Steve Ballmer as president of Microsoft but remaining as Chair and CEO himself. The company released an update to the consumer version of Windows, Windows 98. Windows 98 came with Internet Explorer 4.0 SP1 (which had Windows Desktop Update bundled), and included new features from Windows 95 OSR 2.x including the FAT32 file system, and new features designed for Windows 98, such as support for multiple displays. Microsoft launched its Indian headquarters as well, which would eventually become the company's second largest after its U.S. headquarters. Finally, a great deal of controversy took place when a set of internal memos from the company were leaked on the Internet. These documents, colloquially referred to as "The Halloween Documents", were widely reported by the media and went into detail of the threats that free software / open source software poses to Microsoft's own software, previously voiced mainly by analysts and advocates of open source software. The documents also alluded to legal and other actions against Linux as well as other open source software. While Microsoft acknowledged the documents, it claimed that they are merely engineering studies. Despite this, some believe that these studies were used in the real strategies of the company.