ffer a multiarea pass, now covering all four ski areas. Revenues were divided based on the number of tickets redeemed at each mountain, with the share of the revenue allocated to Highlands ranging from a high of 18.5 percent during the 1974-5 season to a low of 13.2 percent in 1976-7. For the 1977-8 season, Ski Co. asked Highlands to fix its compensation at 13.2 percent of the multiarea pass's revenues. Subsequent negotiations increased Highlands's compensation to 15 percent. The following year, Highlands rejected a proposal that would have reduced its share of the total revenue to 12.5 percent. In response, Ski Co. terminated the all-Aspen ticket and instead offered a three-area ticket covering only the ski areas that it owned. In addition, it frustrated Highlands's attempts to reconstruct the four-area ticket by refusing to sell its three-area tickets to Highlands at the full retail price. The Supreme Court held that Ski Co.'s termination of the joint venture constituted monopolization under Section 2 of the Sherman Act. In the process, it upheld the district court's injunction, which required that the parties jointly offer an all-Aspen ticket modeled on a multiarea ticket that Ski Co. offered at another nearby resort area. In SO concluding, though, the Supreme Court declined to follow the doctrinal lead of the court of appeals, which explicitly based its decision on the essential facilities doctrine (472 U.S. at 587-94, 598 n. 23, 599, 605-11, and n. 44). The decision in Aspen Skiing, like the decision in Otter Tail, has been subject to extensive scholarly criticism. Perhaps the most trenchant criticism involves the definition of the appropriate geographic market. The jury found that the relevant product market was "destination ski resort[s]," whose primary clientele is out-of- town vacationers, as opposed to "day ski area[s]," which cater to local residents (472 U.S. at 587, 594, 596 n. 20). By definition, patrons of destination ski resorts are free to choose from among the many ski areas in the western Unite