31 mandate to assure that rates are “just and reasonable”3 to invalidate a rate distinction that was not unreasonably discriminatory. To uproot over a century of interpretation— and with so little explanation—is truly extraordinary. In its interpretation of § 201 the Commission rests its claim of a “threat” to the “virtuous cycle” theory mentioned above: “innovations at the edges of the network enhance consumer demand, leading to expanded investments in broadband infrastructure that, in turn, spark new innovations at the edge,” Order ¶ 7, and the cycle repeats on and on. The key question is what underlies the Commission’s idea that a ban on paid prioritization will lead to more content, giving the cycle extra spin (or, equivalently, reducing the drag caused by paid prioritization). Order ¶ 7. In what way will an across-the-board ban on paid prioritization increase edge provider content (and thus consumer demand)? Or, putting it in terms of a “threat,” how does paid prioritization threaten the flourishing of the edge provider community (and thus consumer demand, and thus broadband deployment)? 3 See, e.g., Interstate Commerce Act of 1887, 24 Stat. 379, § 1 (“All charges made for any service rendered or to be rendered in the transportation of passengers or property as aforesaid, or in connection therewith, or for the receiving, delivering, storage, or handling of such property, shall be reasonable and just; and every unjust and unreasonable charge for such service is prohibited and declared to be unlawful.”); Federal Power Act, 16 U.S.C. § 824d (“All rates and charges made, demanded, or received by any public utility for or in connection with the transmission or sale of electric energy subject to the jurisdiction of the Commission, and all rules and regulations affecting or pertaining to such rates or charges shall be just and reasonable, and any such rate or charge that is not just and reasonable is hereby declared to be unlawful.”)