92 all sectors of the Internet industry to facilitate prudent business planning, without imposing undue burdens that might interfere with entrepreneurial opportunities.” 2015 Open Internet Order, 30 FCC Rcd. at 5796 ¶ 417. The Commission also identified “numerous concerns about the burdens—or, at a minimum, regulatory uncertainty—that would be fostered by a sudden, substantial expansion of the actual or potential regulatory requirements and obligations relative to the status quo from the near-term past,” in which many broadband providers were not subject to any aspect of Title II. Id. at 5839 ¶ 495. In reaching this conclusion, the Commission drew from its experience with the mobile voice industry, which “thrived under a marketbased Title II regime” that included significant forbearance, “demonstrating that robust investment is not inconsistent with a light-touch Title II regime.” Id. at 5799–800 ¶ 423. Full Service Network argues that the Commission’s “prior predictions of ‘vibrant intermodal competition’ . . . ‘cannot be reconciled with marketplace realities.’” Full Service Network Pet’rs’ Reply Br. 10 (quoting 2015 Open Internet Order, 30 FCC Rcd. at 5743 ¶ 330). As we noted above, however, “[a]n agency’s predictive judgments about areas that are within the agency’s field of discretion and expertise are entitled to particularly deferential review, as long as they are reasonable.” EarthLink, 462 F.3d at 12 (internal quotation marks omitted). In this case, the Commission’s predictive judgments about the effect mandatory unbundling would have on broadband deployment were perfectly reasonable and supported by record evidence. Multiple studies provided evidence that mandatory unbundling harmed investment in Europe. Such evidence, combined with the Commission’s experience in using a “light touch” regulatory program for mobile voice,

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