d Hovenkamp (2008a); Hovenkamp (2005); Sullivan and Grimes (2006). Antitrust as Applied to Network Industries distinguished from growth or development as a consequence of a superior product, business acumen, or historic accident" (United States V. Grinnell Corp., 384 U.S. 563, 570-71 (1966)). As a general matter, then, monopolists do not violate Section 2 simply by charging monopoly prices8 or by refusing to deal with a particular party.9 At the same time, the Court has indicated that "[t]he high value that we have placed on the right to refuse to deal with other firms does not mean that the right is unqualified" (Aspen Skiing, 472 U.S. at 601). The essential facilities doctrine is the result of treatise writers' efforts to make sense of early decisions requiring monopolists to deal with their rivals. 10 The doctrine, which made its first explicit appearance in a judicial decision in 1977, imposes a duty on firms controlling effectively irreproducible bottleneck resources to share those resources with their competitors on reasonable terms. 11 Since 1977, lower courts have invoked it with respect to a wide range of different facilities (Lipsky and Sidak 1999). This doctrine is typically traced to the Supreme Court's decision in United States V. Terminal Railroad Ass'n (224 U.S. 383 (1912)), which is usually described as arising from a monopolist railroad's refusal to allow other railroads to run their rolling stock over the only bridge crossing the Mississippi River near St. Louis. A close examination of Terminal Railroad's facts, however, reveals its inaptness as a foundation for limiting a monopolist's unilateral refusal to deal. As an initial matter, the bottleneck in question was controlled not by a monopolist, but rather by a con- sortium of fourteen of the twenty-four railroads terminating traffic in St. Louis. As such, the conduct in question is more properly analyzed under Section 1 of the Sher- man Act, which governs "combination[s] in restraint of trade," (15 U.S.C. § 1), than under Section 2, which appl