largely critical commentary challenging its conceptual validity, its administrabil- ity, and the extent to which it actually benefits consumers. 2 After years of signaling ambivalence about the doctrine,3 3 the Supreme Court once again returned to the subject in Verizon Communications Inc. V. Law Offices of Curtis V. Trinko, LLP. Although the Court found "no need either to recognize or to repudiate" the doctrine, it endorsed many of the criticisms advanced in the commentary (540 U.S. 398, 411 (2004)). United States V. AT&T (Modification of Final Judgment), 552 F. Supp. 131, 1352-53, 1360-61 (D.D.C. 1982), aff'd mem. sub nom. Maryland V. United States, 460 U.S. 1001 (1983); MCI Commc'ns Corp. V. AT&T, 708 F.2d 1081, 1132-33, 1147-48, 1174 (7th Cir. 1983); S. Pac. Commc'ns Co. V. AT&T, 740 F.2d 980, 999, 1007-09 (D.C. Cir. 1984). This suit was the third case brought by the federal government against AT&T (United States V. W. Elec. Co., 1956 Trade Cas. (CCH) g 68,246 (D.N.J. Jan. 24, 1956); United States V. AT&T, No. 6,082 (D. Or. Mar. 26, 1914) (decree), reprinted in Shale 1918). The 1956 suit is also regarded as based on the essential facilities doctrine (Sullivan and Grimes 2006). Werden (1987); Gerber (1988); Areeda (1990); Reiffen and Kleit (1990); Hylton (1991); McGowan (1996); Lipsky and Sidak (1999); Hovenkamp (2005); Areeda and Hovenkamp (2008c). More sympathetic assessments of the essential facilities doctrine also exist. See, e.g., Ratner (1988); Soma et al. (1998); Pitofsky et al. (2002). Aspen Skiing Co. V. Aspen Highlands Skiing Corp., 472 U.S. 585, 611 n. 44 (1985); AT&T V. Iowa Utils. Bd., 525 U.S. 366, 428 (1999) (Breyer, J., concurring in part and dissenting in part). Antitrust as Applied to Network Industries Most striking is the language in Trinko questioning the antitrust courts' insti- tutional competence to implement access remedies. Since the opinion was issued, courts and commentators have struggled to determine how broadly to read this language. Some have suggested that the presence of a re