107 of the action . . . at issue.” Lujan, 504 U.S. at 561. When a person or company that is the direct object of an action petitions for review, “there is ordinarily little question that the action . . . has caused [it] injury, and that a judgment preventing . . . the action will redress it.” Id. at 561–62. Here, however, Alamo seeks pre-enforcement review of the rules, which raises the question of whether it has demonstrated that the rules inflict a sufficiently concrete and actual injury. We conclude that Alamo has made the requisite showing. Pre-enforcement review, particularly in the First Amendment context, does not require plaintiffs to allege that they “will in fact” violate the regulation in order to demonstrate an injury. Susan B. Anthony List v. Driehaus, 134 S. Ct. 2334, 2345 (2014). Standing “to challenge laws burdening expressive rights requires only a credible statement by the plaintiff of intent to commit violative acts and a conventional background expectation that the government will enforce the law.” Act Now to Stop War & End Racism Coalition v. District of Columbia, 589 F.3d 433, 435 (D.C. Cir. 2009) (internal quotation marks omitted). Because “an agency rule, unlike a statute, is typically reviewable without waiting for enforcement,” that principle applies with particular force here. Chamber of Commerce v. FEC, 69 F.3d 600, 604 (D.C. Cir. 1995). Alamo explains that the “Open Internet conduct rules eliminate Alamo’s discretion to manage the Internet traffic on its network.” Portman Decl. ¶ 5. That statement indicates that, were it not for the rules, Alamo would explore alternative methods of managing internet traffic—namely blocking, throttling, or paid prioritization. In the context of this challenge, the company’s “affidavit can only be understood to mean that” if the rules were removed, it would

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