With the dust still swirling from his controversial first issue, publisher Steven Brill, the nation's newest media watchdog, has trained his sights on another big target: Microsoft's Bill Gates.

The new edition of Brill's Content magazine features a police mug shot of the Microsoft chairman taken more than 20 years ago and a cover story that carries the main headline: "Making Bill: How Bill Gates's PR machine helped make him Master of the Universe. And why it's failing him now."The magazine's inaugural issue last month became the talk of legal and media circles because of ethical questions it raised about news leaks by special prosecutor Kenneth Starr and media coverage of the Clinton-Lewinsky matter.

U.S. District Judge Norma Holloway Johnson cited that article in a ruling made public last week that Starr, in repeatedly leaking information to the reporters, had probably violated grand jury secrecy laws.

This month's article about Gates, covering 15 pages, examines Microsoft's "adroit, aggressive" use of public relations techniques to promote the company, its software and Gates himself.

Among other things, it describes his cultivation of key reporters and publications in order to build an image as a visionary and standard-setter in the computer industry.

The article also questions whether news coverage has been colored by journalists' access to Gates or the prospect of losing it.

The police mug photo on the cover carries the caption, "Bill Gates under arrest for a probably minor but still unknown charge in 1977." But the point in publishing it was not to dredge up a 20-year-old arrest, the magazine said.

"The crimes or negligible misdemeanors of the 22-year-old Gates are of marginal interest," Elizabeth Lesly Stevens wrote.

"But it is illuminating to examine how Microsoft's lawyers, public relations experts and Gates himself handled the surfacing of the potentially embarrassing mug shot."

On May 4, Gates displayed it several times life size on projection screens during a speech to the cable industry as proof that almost anything can be found on the Internet.

"But Gates was not telling the truth about how he had come across the photo," Stevens wrote.

Albuquerque police actually alerted Microsoft that Content had asked for the photo; using it in his speech was an "attempt to trump our use of it" that "goes to the heart of our story about the phenomenal reach of Gates's public-relations machine," editorial director Michael Kramer wrote in a companion column in the new issue.

The mug shot can indeed be found on the Internet - on Microsoft's Web site, along with the rest of the slides Gates presented with his speech.

Stevens wrote that Brill's Content was unable to download the file, despite using "nine different business and home computer systems running both Microsoft's browser and Netscape's."

Someone should have called, Microsoft spokesman Dean Katz said; the company would have explained that the slides were prepared in Microsoft's Power Point presentation format, and could be displayed using either the full program or a viewer that is distributed free.

Including the mug shot was not an attempt to blunt Content's impact, Katz said. "He was using this as an example of what's out on the Internet - that's really about it.

"Certainly Bill wasn't embarrassed by this," Katz said. "He thought it was kind of funny."

Whether or not his use of the mug shot was calculated to counter Content, it was hardly the first time Gates has poked fun at himself and the computer industry in public.

Alone and with such celebrities as Martha Stewart, Gates has joked about computers' complexities as a way of explaining how much work remains to make them easier to use and more reliable.

More personal is a montage that skewers his tendency to use the same phrases and verbal mannerisms in speech after speech.

The new magazine is another in a string of high-profile media ventures for Brill. He earlier founded The American Lawyer magazine and the Court TV cable channel.

The first issue of Brill's Content had an initial press run of 225,000 copies, a spokeswoman said; another 50,000 were quickly ordered when demand exceeded supply.

The second issue includes numerous sharp-tongued reactions to the first, including a letter from Starr. Printed in full, it covers more than five pages - not including a response from Brill that consumes nearly a full page itself.

In the Microsoft story, Stevens herself notes that, "Adroit, aggressive PR did not create Bill Gates or Microsoft, nor does the reality of it negate Gates's accomplishments as a businessman or the appeal and supremacy of his company's products.

"But the story of Microsoft's ability to manage its image in the press, as well as its recent failure to do so, is a significant, if subtle and unexamined part of the larger story of how Gates and his company achieved their present dominance."

In fact, many news reports have been published or broadcast over the past several months that explore Microsoft's apparent blunders in the face of mounting pressure from antitrust regulators.

Microsoft itself made a sort of public confession early this year when top executives apologized for certain incendiary remarks and promised to take a more conciliatory tone in the future.

The spate of negative news coverage is no more the public relations "failure" alleged on Content's cover, Katz said, than positive articles are a victory of spin over substance.

In either case, "As we've said all along, we don't control what the press writes," he said.

Public relations is important, he acknowledged, but not more important than the products themselves.

"People don't buy PR; they buy software," he said. "If it doesn't work for them, they don't continue to buy it."