and cost reduction) that the antitrust laws are designed to foster.7 As Hand SO eloquently put it, "[t]he successful competitor, having been urged to compete, must not be turned upon when he wins" (Alcoa, 148 F.2d at 430). As a result, courts have long held that a Section 2 violation requires more than just proof of monopoly power; it also requires proof of exclusionary conduct, defined in one case as "the willful acquisition or maintenance of that power as See, e.g., Standard Oil Co. V. United States, 221 U.S. 1, 61-62 (1911); United States V. Aluminum Co. of Am. (Alcoa), 148 F.2d 416, 429 (2d Cir. 1945). See also United States V. United Shoe Mach. Corp., 110F Supp. 295,342 (D. Mass. 1953) (noting that Section 2 does not criminalize monopolies obtained through "superior skill, superior products, natural advantages, economic or technological efficiency, low margins of profit maintained permanently and without discrimination, or licenses conferred by, and used within, the limits of law, (including patents on one's own inventions, or franchises granted directly to the enterprise by a public authority)"), aff'd mem., 347 U.S. 521 (1954). This reading of Section 2 also draws support from the scant legislative history that exists. In the words of Senator George Frisbie Hoar: I suppose, therefore, a man who merely by superior skill and intelligence got the whole business because nobody could do it as well as he could was not a monopolist, but that it involved something like the use of means which made it impossible for other persons to engage in fair competition, like the engrossing, the buying up of all other persons engaged in the same business. (Cong. Rec. 1890, 21, 4:3,152 U.S. President's Task Force on Antitrust Policy (1968); Williamson (1972); Areeda and Turner (1978); National Commission for the Review of Antitrust Laws and Procedures (1979); Ratner (1988). These proposals draw support for their position from language in United States V. Griffith, 334 U.S. 100, 107 (1948) and Alcoa, 148 F.2d at 428. 7 Areeda an