ss to the entire network, unbundled access ties up only isolated portions of the network. Because networks are complex systems, tying up network elements in one part of the network can have an adverse impact on portions of the network located far from the element being accessed. Like interconnection access, unbundled access also introduces new sources of network flows at places other than customers' premises. The problem is that the interconnection points for unbundled access are far more varied than those for interconnection access. Therefore, unbundled access's impact on the network's cost, capacity, and reliability is likely to be quite unpredictable. Unbundled access also requires the network owner to establish systems for provisioning and metering components deep within its system at points that do not normally serve as external interfaces with other firms. As the protracted 117 See Yoo (2007a) exploring implications of antitrust for network neutrality. Networks in Telecommunications litigation surrounding the provisions of the 1996 Act demonstrates, implementa- tion of unbundled access is unusually complex. Antitrust courts have entertained requests for mandating unbundled access from time to time. For example, the court overseeing the Modification of Final Judgment was asked to approve a proposed modification that would have provided unbundled access to Ameritech's local telephone network in return for allowing Ameritech to offer long-distance service (Huber et al. 1999). As noted earlier, the failure to provide unbundled access also formed the foundation for Trinko. The Supreme Court's Trinko decision was quite critical of the effect that using the antitrust laws to compel unbundled access to a telecommunications network can have on dynamic efficiency. These critiques are discussed at length above and need be revisited only briefly here. Specifically, the Court rejected calls for imposing unbundled access under the antitrust laws because "[c]ompelling [infrastructure] firms to share the source of their ad