t to which wholesale access would benefit consumers is thus far from clear. As noted in the passage from the Areeda and Hovenkamp antitrust treatise quoted in Part I, antitrust law typically allows manufacturers to sell their products directly if they SO choose and does not require them to sell their products to other retailers at wholesale prices. As Areeda and Hovenkamp rightly conclude, "Why price regulation of the output should make any difference is not clear, since customers are no better off by the forced insertion of an intermediary and - if costs increase as a result - they could be worse off." The only exception is if wholesale prices were regulated, in which case vertical integration into retailing might be an attempt to evade rate regulation at the wholesale level (Areeda and Hovenkamp 2008c, pp. 363-65). Courts have been quite reluctant to use the antitrust laws to mandate wholesale access. The closest that the Supreme Court has come to doing SO is Otter Tail, in which the Court required an electric power company to provide wholesale distribution of power to cities seeking to replace the retail distribution franchises they had previously granted to Otter Tail with municipally owned retail distribution power grids. The analogy to wholesale access is not perfect. By seeking to create the infrastructure needed to provide retail distribution, the cities were seeking to do more than just replace the marketing functions provided by Otter Tail. Even so, leading commentators have described the situation presented in Otter Tail as being analogous to wholesale access (Areeda and Hovenkamp 2008c). As noted earlier, scholarly commentators have raised serious doubts about Otter Tail's vitality as a precedent. The language in Trinko distinguishing Otter Tail on the grounds that "the defendant was already in the business of providing a service to certain customers and refused to provide the same service to certain other customers" arguably suggests a more limited version of wholesale access (540 U.S. at 410). Altho