 exchange service and exchange access, the initial order implementing the 1996 Act declined to subject packet switches to UNE access requirements and ruled that collocation did not extend to equipment used to provide enhanced services, although it included multifunction equipment supporting both conventional telephone and enhanced services SO long as it was necessary to providing conventional telephone service. Furthermore, any company obtaining interconnection or UNE access to provide telecommunications services may offer information services through the same arrangement. The order did US West Communications, Inc. V. FCC, No. 98-1410 (D.C. Cir. Aug. 25, 1999). Networks in Telecommunications mandate UNE access to all loops connecting central offices to end users, including the loops used to provide DSL. The order obligated incumbent local telephone companies to fulfill any requests to condition existing loops to make them DSL- compatible (FCC 1996c). A subsequent order confirmed that collocation included multifunction equipment that could be used to provide both voice and data services (FCC 1999c). Perhaps most importantly, the FCC's Line Sharing Order mandated UNE access to the high-frequency portion of the loop used to carry DSL SO that two competitors could provide services over the same loop, with one offering conventional telephone service and the other offering DSL (FCC 2000c). The courts soon began to question the breadth of the FCC's rulings, beginning with the Supreme Court's decision in AT&Tv. Iowa Utilities Board, which remanded the initial UNE access rules for construing the "necessary" and "impair" standards too broadly (525 U.S. 366, 387-92 (1999)). On remand, the FCC reiterated that incumbent local telephone companies must condition DSL loops upon request. Although UNE access to loops generally included all attached electronics, the FCC specifically excepted packet switches and DSLAMs, on the grounds that the incum- bents did not maintain a monopoly position with respect to these functions and that