It may seem that we have gone as far as we can go
with vertical tubes, but this isn't quite true.
Suppose that there are two circles
and
that aren't tangent.
Pick a point on
,
move it to
,
and normalize as in the one-circle case above.
is a bona fide circle in the half-plane

Now construct a circle
between
and
that is tangent to
and
.
(See Figure 4.)

Figure 4: Introducing a third circle.
Decompose
into the part
between
and
,
and the part
between
and
.
If we move
the point of tangency of
and
to
,
we can cut
into vertical tubes.
Similarly,
if we move
the point of tangency of
and
to
,
we can cut
into vertical tubes.
As for the boundary between
and
,
we can simply ignore it, since it has measure 0.
In this way, we get a cutting of
into tubes,
some of which are vertical from one point of view and some from another.
Once again,
we conclude that

whereas in fact

Taking a second look at the argument we have just gone through,
we see that it can be simplified as follows:
Cut
into the two pieces
and
.
We already know that

and

By the cutting law,