In two-dimensional electronic systems, direct first-order phase transitions are prohibited as a consequence of the long-range Coulomb interaction, which implies a stiff energetic penalty for macroscopic phase separation. A prominent proposal is that any direct first-order transition is instead replaced by a sequence of ``microemulsion" phases, in which the two phases are mixed in patterns of mesoscopic domains. In this note, we comment on the range of average electron density that such microemulsion phases may occupy. We point out that, even without knowing the value of a phenomenological parameter associated with surface tension between the two phases, one can place a fairly strong upper bound on the value of . We make numerical estimates for in the case of the Fermi liquid to Wigner crystal transition and find to be on the order of ,cm. This value is much smaller than the width of the phase transition observed in experiments, suggesting that disorder is a more likely explanation for the apparent broadening of the transition.

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