55 service—and the interconnection arrangements necessary to provide it—as a telecommunications service. IV. We now turn to the Commission’s treatment of mobile broadband service, i.e., high-speed internet access for mobile devices such as smartphones and tablets. As explained above, the Commission permissibly found that mobile broadband— like all broadband—is a telecommunications service subject to common carrier regulation under Title II of the Communications Act. We address here a second set of provisions that pertain to the treatment of mobile broadband as common carriage. Those provisions, found in Title III of the Communications Act, segregate “mobile services” into two, mutually exclusive categories: “commercial mobile services” and “private mobile services.” 47 U.S.C. § 332(c). Providers of commercial mobile services—mobile services that are, among other things, available “to the public” or “a substantial portion of the public”—are subject to common carrier regulation. Id. § 332(c)(1), (d)(1). Providers of private mobile services, by contrast, “shall not . . . be treated as [] common carrier[s].” Id. § 332(c)(2). In 2007, the Commission initially classified mobile broadband as a private mobile service. At the time, the Commission considered mobile broadband a “nascent” service. 2007 Wireless Order, 22 FCC Rcd. at 5922 ¶ 59. In the 2015 Order we now review, the Commission found that, “[i]n sharp contrast to 2007,” the “mobile broadband marketplace has evolved such that hundreds of millions of consumers now use mobile broadband to access the Internet.” 2015 Open Internet Order, 30 FCC Rcd. at 5785 ¶ 398. The Commission thus concluded that “today’s mobile broadband

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