The Second Circuit has upheld a trial court decision rejecting The New Phone Co.’s challenge to a New York City ordinance that regulates pay phone installation on public property. (The city claims no authority to regulate pay phone installation on private property.) The plaintiff alleged that because Verizon had locked up all of the good locations, the city’s ordinance eliminated competition in violation of the Telecommunications Act and the antitrust laws. The Second Circuit held that the Act created safe harbors for state and local regulatory efforts and that the city was immune from antitrust liability under the state action doctrine.