69 from Harold Feld, et al., Public Knowledge to Marlene H. Dortch, FCC, at 10, GN Dkt. Nos. 14-28 & 10-127 (Dec. 19, 2014) (“Public Knowledge 12/19 Letter”). Commenters drew the Commission’s attention to its recognition in 2007 that “mobile broadband available with a standard mobile phone of the time ‘enable[d] users to access a limited selection of websites’ and primarily offered extremely limited functionality such as email.” Id. (citing 2007 Wireless Order, 22 FCC Rcd. at 5906 ¶ 11 & n.43). Because of those limitations, “[i]ndependent ‘app stores’ that allow for seamless downloading and integration of standalone applications [e.g., VoIP applications] into the customer’s handset did not exist” in 2007. Id. The Commission also noted that, today, mobile broadband is dramatically faster: the average network connection speed “exploded” in just three years, going from an average connection speed of 709 kilobytes per second (kbps) in 2010 to an average speed of 2,058 kbps for all devices and 9,942 kbps for smartphones by 2013. 2015 Open Internet Order, 30 FCC Rcd. at 5636 ¶ 89 & n.170. Partly as a result, access to the internet and applications on one’s mobile phone is no longer confined to a small number of functions. Rather, “there has been substantial growth” even since 2010—far more so since 2007—“in the digital app economy . . . and VoIP” in particular. Id. at 5626 ¶ 76. In addition, the Commission cited a letter which explained that, because VoIP applications (such as FaceTime on Apple devices and Google Hangouts on Android devices) now come “bundled with the primary operating systems available in every smartphone,” they are no longer “rare and clearly functionally distinct” as they were in 2007. Letter from Michael Calabrese, Open Technology Institute, et al., to Marlene H. Dortch, FCC, at 6, GN Dkt. Nos. 14-28 & 10-127