The variability observed in many complex gamma-ray bursts (GRBs) is inconsi
stent with causally connected variations in a single, symmetric, relativist
ic shell interacting with the ambient material ("external shocks"). Rather,
either the central site must produce similar to 10(50) ergs s(-1) for hund
reds of seconds ("internal shocks"), or the local spherical symmetry of the
shell must be broken on an angular scale much smaller than Gamma(-1), wher
e Gamma is the bulk Lorentz factor for the shell. The observed variability
in the external shock models arises from the number of causally connected r
egions that (randomly) become active. We define the surface filling factor
to be the ratio of the area of causally connected regions that become activ
e to the observable area of the shell. From the observed variability in 52
BATSE bursts, we estimate the surface filling factor to be typically simila
r to 5 x 10(-3), although some values are near unity. We find that the surf
ace filling factor, f, is similar to 0.1 Delta T/T in both the constant Gam
ma phase (which probably produces the GRB) and the decelerating phase (whic
h probably produces the X-ray afterglows). Here, AT is a typical timescale
of variability, and T is the time since the initial signal. We analyze the
2 hr flare seen by ASCA 36 hr after the GRB and conclude that the surface f
illing factor must be small(10(-3)) in the X-ray afterglow phase as well. C
ompared with the energy required for an isotropic shell, E-iso, explanation
s for a low surface filling factor can either require more energy (f(-1) E-
iso similar to 10(56) ergs) or less energy [(Delta T/4T)E-2(iso) similar to
10(49) ergs]. Thus, the low filling factor cannot be used as a strong argu
ment that GRBs must be internal shocks.