ion over claims seeking access to telecommunications networks. A number of early courts relied on primary jurisdiction to require that antitrust courts defer their consideration of requests for access until after they Younger V. Harris, 401 U.S. 37, 44, 46 (1971). 66 Middlesex County Ethics Comm. V. Garden State Bar Ass'n, 457 U.S. 423, 431-37 (1982). Ohio Civil Rights Comm'n V. Dayton Christian Sch., Inc., 477 U.S. 619, 627-28 (1986). Rizzo V. Goode, 423 U.S. 362, 378-80 (1976). NOPSI, 491 U.S. at 370-71. GTE N., Inc. V. Strand, 209 F.3d at 921; Bell Atl.-Pa., 107 F. Supp. 2d at 666. 71 See, e.g., United States V. W. Pac. R.R., 352 U.S. 59, 65-69 (1956); Pan Am. World Airways, Inc. V. United States, 371 U.S. 296, 309-12 (1963); Ricci V. Chi. Mercantile Exch., 409 U.S. 289, 302-06 (1973). Networks in Telecommunications addressed by the FCC. 72 Later decisions have accorded antitrust courts a greater scope of authority. For example, the district court hearing the case that would lead to the breakup of AT&T took a narrower view of primary jurisdiction, permitting the antitrust case to go forward while reserving the right to refer issues to at a later point in the litigation. 73 This position had the effect of bringing the doctrine of primary jurisdiction more into line with the other doctrines discussed above. C. The Rationales Underlying the Balance between Antitrust and Regulation Over the years, the Supreme Court has offered several justifications for its doctrines allocating decisionmaking authority between antitrust courts and administrative agencies. First and foremost is the need to avoid conflict between the mandates of the antitrust courts and those of the relevant regulatory regime. With respect to immunity implied from other federal statutes, the Court has held that the law must ensure that "the federal agency entrusted with regulation in the public interest could carry out that responsibility free from the disruption of conflicting judgments that might be voiced by courts exercising jurisdiction under t