22 does announce a “nonexhaustive list” of seven factors to be used in assessing providers’ practices, including “end-user control,” “consumer protection,” “effect on innovation,” and “free expression.” Order ¶¶ 138-45. But these factors themselves are vague and unhelpful at resolving the uncertainty. The Commission made an effort to palliate the negative effect of its “standards” by establishing a procedure for obtaining advisory opinions. Order ¶¶ 229-39. It delegated authority to issue such opinions to its Enforcement Bureau, perhaps thereby telegraphing its general mindset on how broadly it intends its prohibitions to be read. But the Bureau has complete discretion on whether to provide an answer at all. Order ¶ 231. Further, any advice given will not provide a basis for longterm commitments of resources: the Bureau is free to change its mind at will, and as the opinions will be issued only at the staff level, the Commission reserves its freedom to act contrary to the staff’s conclusions at any time. Order ¶ 235. I do not understand this to mean that the Commission will seek penalties against parties acting in reliance on an opinion while it is still in effect, but parties in receipt of a favorable opinion are on notice that they may be forced to shut down a program the minute the Bureau reverses itself or the Commission countermands the Bureau. Besides affording rather fragile assurance, the advisory process promises to be slow. “[S]taff will have the discretion to ask parties requesting opinions, as well as other parties that may have information relevant to the request or that may be impacted by the proposed conduct, for additional information.” Id. ¶ 233. Given these possible information requests from various parties, including adverse ones, it is unsurprising that the Commission is unwilling to give any timeliness commitment, explicitly “declin[ing] to establish