s on Attaching Devices Another area of controversy centers on restrictions on end users' right to attach devices, such as consoles for graphics-intensive computer games, Internet phones, and WiFi routers. On some occasions, network providers have prohibited the attachment of certain equipment altogether. On other occasions, providers have required customers wishing to attach such equipment to pay additional charges. The economics of congestion reveals why such measures may be quite sensible when transaction costs render usage-sensitive pricing infeasible. To the extent that online gaming consoles, Internet telephones, and home networking equipment are associated with bandwidth-intensive applications, prohibiting them or requiring end users employing them to pay more for their use may represent a sensible use of proxies for high-volume uses. The absence of such limits will increase the cost of access, thereby reducing the number of people able to connect to the Internet. It will also effectively allow high-volume users to free ride on the contributions made by low-volume users. The restrictions on attaching devices to the Internet are in some tension with the FCC's historical approach to the attachment of handsets and other customer premises equipment (CPE) to the public telephone network. With respect to tele- phony, both the D.C. Circuit's Hush-a-Phone and the FCC's Carterfone decisions recognized the customer's right to interconnect any device that would improve the utility of the telephone system "so long as the interconnection does not adversely affect the telephone company's operations or the telephone system's utility for oth- ers" (FCC 1968; Hush-a-Phone Corp. V. United States, 238 F.2d 266, 269 (D.C. Cir. 1956)). The FCC later promulgated rules (commonly known as the "Part 68" rules after their location in the Code of Federal Regulations) that allow the intercon- nection of any device that complies with certain designated standards (47 C.F.R. §S 68.1-.614 (2004)). As part of the second Computer Inquiry, t