wound to a close yesterday.

Lawyers for both sides spent a full day defining the meaning of "freedom to associate'' and "freedom of association'' as they presented their final submissions.

BTC lawyer Mark Diel was appealing the February Supreme Court decision of Puisne Judge Vincent Meerabux that compels the company to interconnect with Quantum.

The Court of Appeal judges heard submissions from Solicitor General William Pearce and Quantum's consul, Tim Marshall. Both men refuted claims by Mr. Diel that an "association'' exists between the two parties simply because of the interconnection.

BTC, which lodged the appeal, claims the section of the Telecommunications Act which forces it to interconnect with Quantum, in essence, forces it to have dealings with or "associate'' with a company against their will.

They maintained that this denied them of their constitutional right of "freedom to associate'' or do business with whomever they choose.

Both Mr. Pearce and Mr. Marshall contended that Mr. Diel's interpretation of the word "associate'' was too wide. Mr. Marshall argue that it went outside the "constitutional'' meaning.

In laying out his position on what "constitutional association'' is, Mr.

Marshall held that it can only exist between individuals and not activities or objects. He noted Quantum and BTC are not engaged in any joint venture and remain competitors. He further advanced the point that any disconnection by BTC of the present interconnection, would only serve to "frustrate Government's policy of competition''.

The Court of Appeal judges were quick to point out that their function is to consider the constitutionality of BTC's argument and not concern themselves with the intent of Government policy.

The court reserved judgment.

BUSINESS BUC