son Parish, 466 U.S. at 36 n. 4 (O'Connor, J., concurring in judgment); Byars, 609 F.2d at 861; Olympia Equip. Leasing Co. V. W. Union Tel. Co., 797 F.2d 370, 374 (7th Cir. 1986); Bowman (1957); Brennan (1987); Ratner (1988); Joskow and Noll (1999); Farrell and Weiser (2003). Brenner (1996); Farrell (1996); Sullivan (1996); Huber et al. (1999); Joskow and Noll (1999). 38 Werden (1987); Gerber (1988); Ratner (1988); Areeda and Hovenkamp (2008c). Networks in Telecommunications significance. As an initial matter, it has no applicability to wireless and broadband communications, which are not subject to rate regulation. 39 The emergence of competitive wireline alternatives has caused federal and state regulators to dereg- ulate almost all aspects of conventional wireline telephone service provided to businesses. Competition from wireless providers and Voice over Internet Protocol (VoIP) has led state regulatory authorities to begin the process of deregulating wire- line residential telephone services as well (Tardiff 2007). Once this transformation is complete, the Bell Doctrine will cease to have any continuing application to the telecommunications industry. In the absence of some anticompetitive explanation for vertical exclusion, what explains why firms engage in the practice? Even post-Chicago economic theorists recognize that vertical exclusion can yield substantial efficiencies. 40 Some efficien- cies are attributed to technological effects. Building on the copper ingot example introduced above, if the input monopolist sold ingot into the open market, pur- chasers would have to incur the costs of reheating the ingot before fabricating it into pipe. A vertically integrated operation could reduce costs by beginning the pipe fabrication process while the ingot was still hot, although presumably these arrangements could be made between independent firms absent transaction costs. To use another example more closely related to the telecommunications industry, the Federal Communications Commission (FCC) attempted to p