 at 1124; Sound, 631 F.2d at 1330-31; Phonetele, 664 F.2d at 733-34; MCI, 708 F.2d at 1103-05; United States V. AT&T, 461 F. Supp. at 1326-28; Jarvis, 481 F. Supp. at 123-24. 57 FTC V. Ticor Title Ins. Co., 504 U.S. 621, 638 (1992). DFW Metro Line Servs. V. Sw. Bell Tel. Co., 901 F.2d 1267, 1269 n. 6 (5th Cir. 1990); Sonitrol of Fresno, Inc. V. AT&T, 629 F. Supp. 1089, 1094-1101 (D.D.C. 1986); Metro Mobile CTS, Inc. V. NewVector Commc'ns, Inc., 661 F. Supp. 1504, 1508-21 (D. Ariz. 1987), aff'd on other grounds, 892 F.2d 62 (9th Cir. 1989); Davis V. S. Bell Tel. & Tel. Co., 755 F. Supp. 1532, 1539-42 (S.D. Fla. 1991). 59 For long distance services, see Mid-Tex. Commc'ns, 615 F.2d at 1381-82; Modification of Final Judgment, 552 F. Supp. at 156-59. For CPE, see Essential Commc'ns, 610 F.2d at 1125; Sound, 631 F.2d at 1331-35; Phonetele, 664 F.2d at 735-7; Jarvis, 481 F. Supp. at 124. 60 Iowa Utils. Bd., 525 U.S. at 37 n. 6. Networks in Telecommunications retail services. As this process proceeds to its logical conclusion, the basis for state action immunity will eventually disappear. b. Doctrines Affecting the Timing of Antitrust Scrutiny The foregoing discussion reveals that the existing state and federal regulatory schemes are unlikely to insulate telecommunications companies from claims seek- ing access to their networks under the antitrust laws. Although the presence of regulatory schemes may not provide antitrust immunity, it may nonetheless fore- stall judicial consideration of the merits of claims until after the relevant agency has had the opportunity to address the issues in the first instance. Abstention. When the regulatory regime at issue arises under state law, the timing of judicial consideration is determined by one of two abstention doctrines. The first, known as administrative or Burford abstention,61 applies when "the exercise of jurisdiction by the federal court would disrupt a state administrative process" (County of Allegheny V. Frank Mashuda Co., 360 U.S. 185, 189 (1959)). 62 The Supreme Court 