ders were natural strategic partners for companies wishing to enter into local telephone service, yet they had no incentive to undertake such investments SO long as the antitrust decree breaking up AT&T provided them with access to the existing network. The recent patterns of investment following the Supreme Court's Brand X decision bear out this dynamic. Once the Supreme Court made it clear that regulation would no longer guarantee providers of complementary ser- vices access to existing broadband networks, content and application providers and device manufacturers began pouring capital into alternative network technologies such as wireless broadband and broadband over powerlines. Proper administra- tion would thus require the court to monitor technological developments in the telecommunications industry and to release the local telephone companies from their equal access obligations the minute that competition from other local tele- phone companies became sustainable. It is doubtful that any antitrust court, no matter how well intentioned, would be up to such a task. Despite these problems, platform access represents the most common form of access imposed under the antitrust laws. For example, MCI's and the government's antitrust suits against the Bell System both attempted to promote competition in the complementary service of long distance by mandating platform access to the Bell System's local telephone networks. The order breaking up AT&T also extended this equal access requirement to the predecessors to the providers of Internet content (then called information service providers). 108 Although the Modification of Final Judgment did not initially address platform access for CPE, later modifications brought CPE within the equal access mandate as well. ¹09 The court also imposed similar equal access requirements on GTE, the largest non-Bell provider of local telephone service, when approving its merger with Sprint. 110 The proposed consent decree that would have approved AT&T's 1994 acquisition of the largest