subscribers. Different states looked at virtual NXX differently. It took off and was widely deployed in most of the urban coastal states before anyone really could stop it. But in 2000, the Maine Public Utilities Commission (PUC) ruled that WorldCom subsidiary Brooks Fiber had violated state rules with its "remote exchange" VNXX service. The PUC was upset that Brooks had taken over 50 prefix codes from the state's one area code, while it was only physically located in Portland, refused to serve customers physically outside of Portland, and was in fact only authorized to serve the Portland area. It held that calls to those non- local numbers were, in fact, interexchange and subject to switched access charges. Brooks had to phase out the service and return most of its prefix codes to the North American Numbering Plan Administration. Shortly afterwards, the South Carolina PUC made a similar ruling against Adelphia Business Solu- tions. Those states were the exceptions, but some other rural states had no vir- tual NXX CLECs, even absent a formal ruling. The New Hampshire PUC issued a more nuanced ruling in 2003. It rec- ognized that ISP-bound calls were, according to the FCC, exempt from switched access charges. (Whether the FCC's long-standing "ESP exemption" applied to geographically nonlocal calls was an interesting question that states did not always agree upon.) But it did not want to waste prefix codes for virtual NXX. So it ruled that a CLEC could not have a prefix code rated to an exchange in which none of its subscribers were physically located-the traditional mean- ing of virtual NXX. But it allowed the CLECs to have a single oddball NXX code for ISP use that would be local to the entire state, the "information access NXX." Had such a rule been adopted in 1996, the country would no doubt have had far fewer area code splits, and the CLECs would still have been able to service ISPs during the dial-up boom. By 2003, though, the number of dial-up users was already in decline. Besides the prefix aggregation of v