47 offering of an information service, in the present order the Commission cited ample record evidence supporting its current view that consumers perceive a standalone offering of transmission. See supra at 25–27. It thus satisfied the APA’s requirement that an agency provide a “reasoned explanation . . . for disregarding facts and circumstances that underlay . . . the prior policy.” Fox Television, 556 U.S. at 515–16. Nothing more is required. Presenting an argument quite similar to US Telecom’s, the partial dissent asserts that the Commission needed to do more than justify its current factual findings because, in this case, “the agency explicitly invoke[d] changed circumstances” as a basis for reclassifying broadband. Concurring & Dissenting Op. at 10. At least when an agency relies on a change in circumstances, the partial dissent reasons, “Fox requires us to examine whether there is really anything new.” Id. at 4. But we need not decide whether there “is really anything new” because, as the partial dissent acknowledges, id., the Commission concluded that changed factual circumstances were not critical to its classification decision: “[E]ven assuming, arguendo, that the facts regarding how [broadband service] is offered had not changed, in now applying the Act’s definitions to these facts, we find that the provision of [broadband service] is best understood as a telecommunications service, as discussed [herein] . . . and disavow our prior interpretations to the extent they held otherwise.” 2015 Open Internet Order, 30 FCC Rcd. at 5761 ¶ 360 n.993. US Telecom next argues that the Commission “could not rationally abandon its prior policy without account[ing] for reliance interests that its prior policy engendered.” US Telecom Pet’rs’ Br. 51 (alteration in original) (internal quotation marks omitted). The Commission, however, did not

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