71 technological and functional integration of VoIP applications—mobile broadband should now be considered interconnected with the telephone network. Indeed, even for communications from one mobile broadband user to another, mobile broadband generally works in conjunction with a native or third-party application of some sort (e.g., an email application such as Gmail or a messaging application such as WhatsApp) to facilitate transmission of users’ messages. The conjunction of mobile broadband and VoIP to enable IP-totelephone communications is no different. That is especially apparent in light of the Commission’s regulatory definition of “interconnected service.” The regulation calls for assessing whether mobile broadband “gives subscribers the capability to communicate to” telephone users. 47 C.F.R. § 20.3 (emphasis added). Mobile petitioners do not challenge the Commission’s understanding that a “capability to communicate” suffices to establish an interconnected service, and we see no ground for rejecting the Commission’s conclusion that mobile broadband gives subscribers the “capability to communicate to” telephone users through VoIP. And although the regulation also references “receiv[ing] communications from” others in the network, id., mobile petitioners also do not challenge the Commission’s understanding that the capability either to “communicate to or receive communication from” is enough, id. (emphasis added). Consequently, the capability of mobile broadband users “to communicate to” telephone users via VoIP suffices to render the network—and, most importantly, its users—“interconnected.” Mobile petitioners note what they perceive to be a separate problem associated with communications running in the reverse direction (i.e., the capability of mobile broadband users to “receive communications from” telephone users).

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