14 The Supreme Court upheld the Commission’s classification of cable modem service in National Cable & Telecommunications Ass’n v. Brand X Internet Services, 545 U.S. 967, 986 (2005). Applying the principles of statutory interpretation established in Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), the Court explained that the key statutory term “offering” in the definition of “telecommunications service” is ambiguous. Brand X, 545 U.S. at 989. What a company offers, the Court reasoned, can refer to either the “single, finished product” or the product’s individual components. Id. at 991. According to the Court, resolving that question in the context of broadband service requires the Commission to determine whether the information service and the telecommunications components “are functionally integrated . . . or functionally separate.” Id. That question “turns not on the language of [the Communications Act], but on the factual particulars of how Internet technology works and how it is provided, questions Chevron leaves to the Commission to resolve in the first instance.” Id. Examining the classification at Chevron’s second step—reasonableness—the Court deferred to the Commission’s finding that “the high-speed transmission used to provide [the information service] is a functionally integrated component of that service,” id. at 998, and upheld the order, id. at 1003. Three Justices dissented, arguing that cable broadband providers offered telecommunications in the form of the “physical connection” between their computers and end users’ computers. See id. at 1009 (Scalia, J., dissenting). Following Brand X, the Commission classified other types of broadband service, such as DSL and mobile broadband service, as integrated offerings of information services without a standalone offering of telecommunications. See, e.g., In re Appropriate Regulatory Treatment for