17 but the rate of turnover actually looks quite substantial. The Commission points to average monthly churn rates of 1.56% in mobile broadband across four leading providers. Order ¶ 98 n.211. Assuming that a single person does not switch more than once in a year, that rate of churn means that 18.72% of customers switch providers each year, suggesting quite robust competition. Interestingly, the Commission is especially hard on declines in churn rate, id., which in the absence of increased concentration or some new obstacle to switching might well suggest increased consumer satisfaction. To bolster its switching data claims, the Commission points to documents in which parties to the rulemaking make conclusory assertions purportedly showing that 27 percent of mobile broadband consumers do not switch though “dissatisfied” with their current carriers. Order ¶ 98. Without a plausible measure of “dissatisfaction” (none is offered), the number is meaningless.