recently described Burford abstention as follows: Where timely and adequate state-court review is available, a federal court sitting in equity must decline to interfere with the proceedings or orders of state administrative agencies: (1) when there are difficult questions of state law bearing on policy problems of substantial public import whose importance transcends the result in the case then at bar; or (2) where the exercise of federal review of the question in a case and in similar cases would be disruptive of state efforts to establish a coherent policy with respect to a matter of substantial public concern. (New Orleans Pub. Serv., Inc. V. Council of New Orleans (NOPSI), 491 U.S. 350, 361 (1989) (internal quotation marks omitted)) Lower courts have generally declined to apply Burford abstention to challenges to denial of access to telecommunications networks either because the state law issue was relatively clear63 or because the issue was purely a question of federal law.64 As a result, there was little risk of disrupting the policies reflected in the state administrative processes. The second, known as Younger abstention, is based on the premise that the federal government should not interfere with those governmental functions that are more properly regarded as falling within the province of the states under the system Burford V. Sun Oil Co., 319 U.S. 315, 317-18 (1943) (establishing doctrine); Bator et al. (1988, p. 1364), calling the form of abstention initiated by Burford "administrative abstention" (internal quotation marks omitted). See also Lumbermen's Mut. Cas. Co. V. Elbert, 348 U.S. 48, 53 (1954); Zwickler V. Koota, 389 U.S. 241, 249 n. 11 (1967). 63 GTE N., Inc. V. Strand, 209 F.3d 909, 920-21 (6th Cir. 2000). 64 Bell Atl. -Pa., Inc. V. Pa. Pub. Util. Comm'n, 107 F. Supp. 2d 653, 665-66 (E.D. Pa. 2000). Antitrust as Applied to Network Industries of federalism established by the Constitution. The paradigmatic state function into which the federal government should not intrude, illustrated by the 