in Handbook of Telecommunications Economics, vol. 1, edited by Martin E. Cave, Sumit K. Majumdar, and Ingo Vogelsang (Elsevier/North-Holland, 2002), pp. 295-384. 23. The incumbent companies realized the importance of keeping local termination rates low only after new entrants began positioning themselves in front of Internet service providers to "terminate" incoming minutes of Internet connections. Predictably, this highly successful form of arbitrage led to calls for regulators to limit terminating access charges to voice calls. Eventually, regulators closed the arbitrage opportunity, but the incumbents were given a strong message that low, cost-based termination charges were the best choice, even for them. 24. In chapter 4, I show that the use of simple or "total service" resale has lagged severely because of the availability of the unbundled network platform. For avoided costs, see Joan Marsh, AT&T, "UNE-P VS. 271 LD Entry: What's the Real Trade-Off for the RBOCs?" Ex Parte Submission to the FCC, WC Docket 01-338 (September 25, 2002). 25. The chairman of the FCC at that time, Reed Hundt, has written a book on his tenure at the FCC, You Say You Want a Revolution (Yale University Press, 2000), that admits to such a goal in implementing the act. 26. MCI Telecommunications Corp. V. FCC, 561 F. 2d 365 (D.C. Cir. 1977). 27. U.S. Department of Justice and the Federal Trade Commission, Horizontal Merger Guidelines (April 2, 1992; rev. April 8, 1997), sec. 1.51. 28. FCC, Trends in Telephone Service (May 2004), table 1.2. 29. In its last report to the FCC as a regulated company, AT&T reported total market- ing expenses of $4.16 billion in 1994, a year in which it had $36.88 billion in total rev- enues. Its marketing expenses were roughly two-thirds of the total operating costs and depreciation of its entire national network. See FCC, Statistics of Communications Common Carriers, 1994/1995 (1995), pp. 42-43. 30. The 1982 AT&T antitrust decree that spun off the Bell operating companies lim- ited each of the divested Bell 