56 Internet access service, with hundreds of millions of subscribers,” is not a “private” mobile service “that offer[s] users access to a discrete and limited set of endpoints.” Id. at 5788–89 ¶ 404. Rather, “[g]iven the universal access provided today and in the foreseeable future by and to mobile broadband and its present and anticipated future penetration rates in the United States,” the Commission decided to “classify[] mobile broadband Internet access as a commercial mobile service” subject to common carrier regulation. Id. at 5786 ¶ 399; see generally id. at 5778–88 ¶¶ 388–403. Petitioners CTIA and AT&T (“mobile petitioners”) challenge the Order’s reclassification of mobile broadband as a commercial mobile service. In their view, mobile broadband is, and must be treated as, a private mobile service, and therefore cannot be subject to common carrier regulation. We reject mobile petitioners’ arguments and find that the Commission’s reclassification of mobile broadband as a commercial mobile service is reasonable and supported by the record. A. In assessing whether the Commission permissibly reclassified mobile broadband as a commercial rather than a private mobile service, we begin with an overview of the governing statutory and regulatory framework and of the Commission’s application of that framework to mobile broadband. The statute defines “commercial mobile service” as “any mobile service . . . that is provided for profit and makes interconnected service available (A) to the public or (B) to such classes of eligible users as to be effectively available to a substantial portion of the public, as specified by regulation by the Commission.” 47 U.S.C. § 332(d)(1). The statute then defines “private mobile service” strictly in the negative, i.e., as “any mobile service . . . that is not a

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