 striking parallels to the debate over vertical integration under the antitrust laws described in Chapter 4. Until the mid-1970s, the Supreme Court clearly embraced a vision of competition quite similar to that espoused by network neutrality proponents. Fueled by a scholarly literature that was largely distrustful of vertically integrated enterprises, the Supreme Court invalidated a wide range of exclusivity arrange- ments on the grounds that they infringed on consumers' freedom of choice. 25 The Court invalidated other exclusivity arrangements as impermissible restrictions on manufacturers' ability to access all channels of distribution. 26 Over time, however, the Court began to realize that this atomistic vision of competition often exacted a steep price. Economic theorists began to identify cir- cumstances under which vertical integration and vertical contractual restraints could promote efficiency, either by eliminating downstream monopoly pricing or by rationalizing the proportions of variable inputs. Even more important was the Wu (2003); Frischmann and van Schewick (2007). 25 Times-Picayune Publ'g Co. V. United States, 345 U.S. 594, 605 (1953); FTC V. Brown Shoe Co., 384 U.S. 316, 321 (1966). 26 Klor's, Inc. V. Broadway-Hale Stores, Inc., 359 U.S. 207, 212-13 (1959); Albrecht V. Herald Co., 390 U.S. 145, 152-53 (1968), overruled by State Oil Co. V. Khan, 522 U.S. 3 (1997); United States V. Topco Assocs., Inc., 405 U.S. 596, 610-11 (1972). Networks in Telecommunications realization that vertical integration and vertical restraints could also yield trans- action cost efficiencies that could not be realized in the world of unfettered buyer and trader freedom. In particular, economists began to recognize how vertical inte- gration and vertical contractual restraints that simulate vertical integration (such as exclusive dealing contracts, tying, and territorial exclusivity) can reduce the transaction costs needed to protect against opportunism. The Supreme Court eventually embraced this emerging vision in its l