ere changing their tune. Calls to ISPs were not, after all, local and should not, they insisted, be subject to reciprocal compensation. In some states the ILECs practiced "self- help" and simply stopped paying CLECs that served ISPs. Thus began a long round of state-by-state hearings on the issue. More often than not, the CLECs won at the state level, at least initially, retaining reciprocal compensation in California, Florida, and New York. In February 1999, the FCC held that ISP- bound calls were jurisdictionally interstate because the end-to-end payload of an Internet connection was often out of state. This weakened the "two-call" the- ory, that a call to an ISP was an example of local telecommunications whose pay- load was a distinguishable example of interstate communications [7]. But that did not, by itself, end reciprocal compensation. The ILECs then won a major vic- tory in Massachusetts, whose Department of Telecommunications and Energy reversed its earlier position and decided, on the basis of that FCC ruling, that ISP-bound calls should not receive reciprocal compensation [9]. That decision established a rebuttable presumption that if a CLEC's traffic were more than 2:1 inbound, then the excess was ISP-bound. That hand-waving got around the issue of determining just what was an ISP-bound call, since ISPs are not regu- lated or licensed as such and thus do not technically have to identify themselves to LECs. The Grandfather Clause Locked Out New Entrants and Squeezed the Old In April 2001, the FCC issued a new ISP ruling that once again affirmed the interstate nature of ISP-bound calls. It adopted the Massachusetts model of using a traffic ratio, 3:1 by default, to identify ISP-bound calls. But it allowed states to leave in place existing reciprocal compensation arrangements, if they SO chose, subject to a cap on the number of compensable minutes. That grandfa- ther clause kept newcomers out of the business; new CLECs got no reciprocal compensation for ISP-bound calls because their cap was zero. Recipro