81 Marlene H. Dortch, FCC, GN Dkt. Nos. 14-28 & 10-127 (Dec. 24, 2014); Public Knowledge 12/19 Letter; Letter from Michael E. Glover, Verizon, to Marlene H. Dortch, FCC, GN Dkt. Nos. 14-28 & 10-127 (Oct. 29, 2014); OTI 12/11 Letter; Letter from William H. Johnson, Verizon, to Marlene H. Dortch, FCC, GN Dkt. Nos. 14-28 & 10-127 (Oct. 17, 2014). In those exchanges, mobile petitioners raised and fiercely debated all of the same arguments they now raise before us, thus demonstrating not only the presence of actual notice, but also the absence of new arguments they might present to the Commission on remand. Indeed, when asked at oral argument, mobile petitioners could not list any new argument on the issue of the redefinition of public switched network. See Oral Arg. Tr. 74–79, 84–87. Mobile petitioners also allege that the Commission gave inadequate notice of the removal of “all” from the definition of interconnected service. Any such failure, however, was also harmless. As noted above, not only does the Commission claim that the removal of “all” was inconsequential to the regulation, but that adjustment also has no bearing on our decision to uphold the Commission’s reclassification decision. We would uphold the Commission’s decision regardless of whether the Commission validly removed “all” from the definition of “interconnected service.” Mobile petitioners thus cannot show prejudice from any lack of notice. See Steel Manufacturers Ass’n v. EPA, 27 F.3d 642, 649 (D.C. Cir. 1994) (explaining that inability to comment on one rationale for rule was harmless when agency had “adequate and independent grounds” for rule). Mobile petitioners, for those reasons, fail to show the prejudice required by the APA to succeed on their arguments of insufficient notice. We therefore reject their challenges.