he antitrust laws" (United States V. Nat'l Ass'n of Sec. Dealers (NASD), 422 U.S. 694, 734 (1975)). It has invoked similar rationales in the context of state action immunity,74 Burford abstention, and primary jurisdiction. In the context of state action immunity, the Supreme Court also has invoked federalism as an additional consideration. As the Court noted in Parker, "In a dual system of government in which, under the Constitution, the states are sovereign, save only as Congress may constitutionally subtract from their authority, an unexpressed purpose to nullify a state's control over its officers and agents is not lightly to be attributed to Congress" (317 U.S. at 351). The Court based Younger abstention on notions of "comity" and "Our Federalism," which it described as "a proper respect for state functions, a recognition that the entire country is made up of a Union of separate [States], and a continuance of the belief that the National Government will fare best if the States are left free to perform their separate functions in their separate ways" (401 U.S. at 44). The inclusion of federalism as a justification with respect to these two doctrines, though, did not make them any broader than when For an invocation of primary jurisdiction in an antitrust suit challenging AT&T's refusal to allow independent long distance companies to connect with its network, see MCI Commc'ns Corp. V. AT&T, 496 F.2d 214, 219-24 (3d Cir. 1974). For invocations of primary jurisdiction in the context of CPE, see Carter V. AT&T, 250 F. Supp. 188, 190-92 (N.D. Tex. 1966), aff'd, 365 F.2d 486 (5th Cir. 1966); cases collected in Huber et al. (1999, pp. 664-65); see also Carter, 365 F.2d at 498 n. 23 (citing four unreported district court cases in which courts invoked doctrine of primary jurisdiction when confronted with antitrust challenges to foreign attachments tariffs). United States V. AT&T, 427 F. Supp. 57, 61-62 (D.D.C. 1976); United States V. AT&T, 461 F. Supp. at 1329, 1336, 1349-50. Cantor V. Detroit Edison Co., 428 U.S. 579,