ies to single-firm action. Furthermore, the initial bridge owned by the supposed monopolist actually faced competition from a sec- ond bridge as well as three ferry companies, each of which the consortium acquired as part of a concerted effort to foreclose competition. 12 Thus, as the Supreme Court would ultimately recognize in Trinko, the conduct at issue in Terminal Railroad Trinko, 540 U.S. at 407; Berkey Photo, Inc. V. Eastman Kodak Co., 603 F.2d 263, 276, 294 (2d Cir. 1979). United States V. Colgate & Co., 250 U.S. 300, 307 (1919). Neale (1960); Sullivan (1977). 11 Hecht V. Pro-Football, Inc., 570 F.2d 982, 992 (D.C. Cir. 1977) (citing Neale 1970, p. 67). For example, when Congress authorized the construction of the second bridge, it attempted to protect against merger to monopoly by prohibiting anyone from owning stock in both bridges. This was repealed in what the United States described as a "mysterious manner" before the Association obtained control of the second bridge (Statement and Brief of the Attorney General of the United States at 53, Terminal R.R. (No. 386); see also Reiffen and Kleit 1990 describing acquisition of second bridge by Association). The Association acquired the ferry companies only after a rival railroad attempted to purchase one of the ferries as part of a plan to begin providing service in St. Louis. The bidding war between the Association and the rival railroad ended when the Association acquired the ferry while simultaneously agreeing to admit the Rock Island and seven other railroads to the consortium (Reiffen and Kleit 1990). Networks in Telecommunications cannot be characterized as the unilateral actions of a solitary monopolist, but rather as the efforts of a cartel pursuing a conscious plan of merger to monopoly (540 U.S. at 410 n. 3). 13 Two other Supreme Court decisions offer more appropriate modern founda- tions for the essential facilities doctrine. The first case, Otter Tail Power Co. V. United States, involved a power company that provided three types of services to a 