t was once quite hostile to agreements giving preferential treatment to certain retailers over others,103 has recognized over time that restrictions on intrabrand competition can promote interbrand competition. As the Supreme Court reasoned in its landmark decision in Continental T.V., Inc. V. Sylvania: Economists have identified a number of ways in which manufacturers can restrictions [on the distribution of their products] to compete more effectively against other manufacturers. For example, new manufacturers and manufacturers entering new markets can use the restrictions in order to induce competent and aggressive retailers to make the kind of investment of capital and labor that is often required in the distribution of products unknown to the consumer. Established manufacturers can use them to induce retailers to engage 102 St. Louis, Iron Mountain & S. Ry. Co. V. S. Express Co. (Express Cases), 117 U.S. 1, 26-29 (1886); Pac. Tel. & Tel. Co. V. Anderson, 196 F. 699, 703 (E.D. Wash. 1912); Areeda and Hovenkamp (2008c); Huber et al. (1999). 103 Eastman Kodak Co. V. S. Photo Materials Co., 273 U.S. 359, 375 (1927) (invalidating exclusive deal- ing contract despite the absence of direct evidence of purpose to monopolize); Standard Stations, 337 U.S. at 314 (striking down exclusive dealing contract that foreclosed 16% of the market); FTC V. Brown Shoe Co., 384 U.S. 316, 320-21 (1966) (rejecting exclusive dealing arrangement involving small fraction of retailers). Networks in Telecommunications in promotional activities or to provide service and repair facilities necessary to the efficient marketing of their products The availability and quality of such services affect a manufacturer's goodwill and the competitiveness of his product. Because of market imperfections such as the so-called "free rider" effect, these services might not be provided by retailers in a purely competitive situation, despite the fact that each retailer's benefit would be greater if all provided the services than if none did. (433 U.S. at 54-