32 providers were common carriers under this court’s NARUC test in order to reclassify. 1. In addressing petitioners’ first argument, we follow the Supreme Court’s decision in Brand X and apply Chevron’s two-step analysis. Brand X, 545 U.S. at 981 (“[W]e apply the Chevron framework to the Commission’s interpretation of the Communications Act.”). At Chevron step one, we ask “whether Congress has directly spoken to the precise question at issue.” Chevron, 467 U.S. at 842. Where “the intent of Congress is clear, that is the end of the matter; for [we], as well as the agency, must give effect to the unambiguously expressed intent of Congress.” Id. at 842–43. But if “the statute is silent or ambiguous with respect to the specific issue,” we proceed to Chevron step two, where “the question for the court is whether the agency’s answer is based on a permissible construction of the statute.” Id. at 843. As part of its challenge to the Commission’s reclassification, US Telecom argues that broadband is unambiguously an information service, which would bar the Commission from classifying it as a telecommunications service. The Commission maintains, however, that Brand X established that the Communications Act is ambiguous with respect to the proper classification of broadband. As the Commission points out, the Court explained that whether a carrier provides a “telecommunications service” depends on whether it makes an “offering” of telecommunications. Brand X, 545 U.S. at 989; see also 47 U.S.C. § 153(53) (“The term ‘telecommunications service’ means the offering of telecommunications for a fee directly to the public . . . .” (emphasis added)). The term “offering,” the Court held, is ambiguous. Brand X, 545 U.S. at 989.