ongoing supervision required by a regulatory decree is aptly demonstrated by Terminal Railroad, in which the Supreme Court was constantly called upon to adjudicate the application of the decree. 84 Although such problems might be minimized if the monopolist already sold the product to other customers, because an antitrust court could simply order that it provide access on a nondiscriminatory basis, 85 evaluating claims of discrimination is notoriously difficult. In any event, this solution is completely unavailing if the bottleneck owner does not sell its input externally and instead devotes all available capacity to its own output. It is easy to make the case that complex subjects such as telecommunications should be the province of administrative agencies and not courts. Agencies enjoy advantages that go beyond technical expertise. Unlike courts, agencies can set their own agendas, and they are less dependent on the parties for the development of the factual record and legal arguments than are courts. Administrative processes also provide greater opportunities for public participation than do judicial processes, in which interested third parties are generally limited to filing amicus briefs. Agencies are also in a better position to take all aspects of a regulatory scheme into account than are courts, which by their nature will limit their consideration to the dispute at hand. Permitting courts to entertain antitrust suits might simply invite disappointed parties who failed to obtain relief from the agency to try to take a second bite of the apple. These considerations suggest that regulatory agencies are in a better position to supervise access mandates than are antitrust courts. As we shall see, these concerns would find voice in the Supreme Court's decision in Trinko. C. The Impact of Trinko The Supreme Court's Trinko decision arose out of a dispute over the speed with which Verizon and its predecessors86 were meeting the obligation that the Telecom- munications Act of 1996 imposed on existing local telephon