Younger case itself, is the prosecution of state crimes. 65 Subsequent decisions have extended Younger to state administrative proceedings implicating important state interests, including attorney malpractice, 66 claims of sex discrimination,67 and misconduct state police and prosecutors. 68 The Supreme Court has noted that Younger has only been applied to administrative proceedings that were essentially backward- looking. Forward-looking proceedings, such as ratemaking, are more closely allied with the legislative than the judicial process and thus are poor candidates for Younger abstention. 69 As a result, lower courts have generally declined to subject challenges to denial of access to telecommunications networks to Younger abstention. 70 Primary Jurisdiction. When the regulatory regime at issue is a federal one, the timing of judicial consideration is determined by a doctrine known as "primary jurisdiction," which requires courts to permit agencies responsible for adminis- tering federal regulatory schemes the opportunity to be the first to address issues within their competence. As a result, the doctrine of primary jurisdiction requires the federal courts to stay its proceedings or dismiss a claim without prejudice until the relevant agency has had a chance to address the issue. The Supreme Court examined the foundations of primary jurisdiction in RCA, which addressed whether the existence of FCC regulation prevented federal courts from considering an antitrust claim: [W]hen rates and practices relating thereto were challenged under the antitrust laws, the agencies had primary jurisdiction to consider the reasonableness of such rates and practices in the light of the many relevant factors including alleged antitrust violations, for otherwise sporadic action by federal courts would disrupt an agency's delicate regulatory scheme, and would throw existing rate structures out of balance. (358 U.S. at 348) Primary jurisdiction is the only doctrine ever to serve as a meaningful limit on antitrust courts' jurisdict