ss of interstate and international tele- phone rates (Statutes at Large 1910, pp. 544-46). Although the Act obligated inter- state telephone providers "to provide service on request at just and reasonable rates, without unjust discrimination or undue preference," it did not give the ICC the authority to require the filing of tariffs or mandate interconnection ex ante, which had the effect of limiting it to ex post review of rates. 2 In addition, with its atten- tion fixed primarily on the railroads, the ICC did little to exercise the regulatory jurisdiction it did possess, undertaking only four telephone rate cases during the twenty-four years during which it had jurisdiction over the telephone industry. Congress addressed many of the deficiencies of the Mann-Elkins Act when enacting the Communications Act of 1934. In addition to giving the newly created Federal Communications Commission the authority to ensure that interstate tele- phone rates were just, reasonable, and nondiscriminatory, the Act also addressed the ICC's lack of authority to require tariffs by requiring all interstate carriers to file schedules of charges. At the same time, the Act preserved the preexisting division between federal and state authority by including language providing that "nothing in this Act shall be construed to apply or to give the Commission jurisdiction with respect to charges, classifications, practices, services, facilities, or regulations for or in connection with intrastate communication service of any carrier." The Act also gave the FCC the authority to oversee what became known as the "separations" process, through which the agency would determine what proportion of the costs of capital equipment used for both local and long distance would be allocated to each service (47 U.S.C. §S 152(b), 1(b), 202(a), 203, 221(c)). 2. The Emergence of Competition in Complementary Services From the time of the enactment of the 1934 Act until the mid-1960s, regulators and the Bell System entered into a symbiotic relationship. The regul