24 Furthermore, 47 U.S.C. § 207, which applies to broadband providers once they are subject to Title II, increases uncertainty yet more. Section 207 allows “[a]ny person claiming to be damaged by any common carrier . . . [to] either make complaint to the Commission . . . , or . . . bring suit for the recovery of the damages for which such common carrier may be liable under the provisions of this chapter.” In other words, reclassification exposes broadband providers to the direct claims of supposedly injured parties, further increasing uncertainty and risk. In short, the Order’s probable direct effect on investment in broadband seems unambiguously negative. As to the hoped-for indirect effect, the idea that it will be positive depends on the supposition that these new rules (the specific and the general) will cure some material problem, will avert some threat that either is now burdening the internet or could reasonably be expected to do so absent the Commission’s intervention. Why, precisely, the observer wants to know, has the Commission repudiated the policy judgment it made in 2002, that “broadband services should exist in a minimal regulatory environment that promotes investment and innovation in a competitive market”? Declaratory Ruling ¶ 5. The answer evidently turns on the Commission’s conclusion that broadband providers have indulged (or will indulge) in behavior that threatens the internet’s “virtuous cycle.” Indeed, the majority points to the need to reclassify broadband so that the Commission could promulgate the rules as the Commission’s “‘good reason’ for [its] change in position,” Maj. Op. 43, and indeed its only reason. But the record contains multiple reasons for thinking that the Commission’s new rules will retard rather than enhance the “virtuous cycle,” and the Commission’s failure to answer those objections renders its decision arbitrary and capricious. I now turn to those arguments, first in the context