88 support, Full Service Network relies on our decision in Bell Atlantic Telephone Cos. v. FCC, 24 F.3d 1441 (D.C. Cir. 1994), in which we refused to uphold under section 201 a Commission rule requiring physical co-location. The rule, we reasoned, would unnecessarily raise Takings Clause issues because the Commission could use virtual co-location, where local exchange carriers maintain equipment that third-party providers can use, to implement section 201’s “physical connection” requirement without raising constitutional issues. Id. at 1446. So while Full Service Network is correct that Bell Atlantic imposes one limit on the Commission’s reach under section 201, that case also demonstrates that the Commission retains authority to regulate network connections under that section. Next, Full Service Network argues that section 152(b), which “prevent[s] the Commission from taking intrastate action solely because it further[s] an interstate goal,” AT&T Corp. v. Iowa Utilities Board, 525 U.S. 366, 381 (1999), prohibits the Commission from “us[ing] its interstate authority under [section] 201 to regulate broadband Internet access service that is an intrastate ‘telephone exchange service’ under the [Communications] Act,” Full Service Network Pet’rs’ Br. 17 (emphasis omitted) (quoting 47 U.S.C. § 153(54)). According to Full Service Network, the Commission erred by refusing to determine whether broadband service qualifies as a “telephone exchange service” because that definition would prevent the Commission from classifying the internet as jurisdictionally interstate. In the Order, the Commission “reaffirm[ed] [its] longstanding conclusion” that broadband service falls within its jurisdiction as an interstate service. 2015 Open Internet Order, 30 FCC Rcd. at 5803 ¶ 431; see Cable Broadband Order, 17 FCC Rcd. at 4832 ¶ 59; In re GTE Telephone

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