Since the 1963 antitrust decision of United States v. Philadelphia National Bank & Trust Co. I the Supreme Court has held that the "cluster" of commercial banking products is the relevant product market or line of commerce in bank merger litigation. The banking cluster as determined by the Court includes various kinds of credit products as well as services, such as checking accounts and trust administration, that are denoted by the term "commercial banking." The significant implication of this approach by the Court is that banks are assumed to compete only with other banks. As a consequence, financial services providers other than banks are excluded from the competitive analysis.