When two telephone companies find themselves in a disagreement over an interconnection arrangement, they must first litigate their dispute before a state utility commission before coming to federal court, the 3rd U.S. Circuit Court of Appeals has ruled.

In Core Communications Inc. v. Verizon Pennsylvania Inc., a unanimous three-judge panel concluded that a lower court had correctly dismissed a claim under the Telecommunications Act of 1996 on the grounds that it had not yet been reviewed by the Pennsylvania Public Utilities Commission.