70 (Dec. 11, 2014) (“OTI 12/11 Letter”); see 2015 Open Internet Order, 30 FCC Rcd. at 5787 ¶ 401 n.1168. Any distinction between calls made with a device’s “native” dialing capacity and those made through VoIP thus has become “increasingly inapt.” OTI 12/11 Letter at 5; see Public Knowledge 12/19 Letter at 10. The Commission accordingly found that “[t]oday, mobile VoIP . . . is among the increasing number of ways in which users communicate indiscriminately between NANP and IP endpoints on the public switched network.” 2015 Open Internet Order, 30 FCC Rcd. at 5787 ¶ 401; see Resp’ts’ Br. 99 (relying on that finding). In light of those developments, the Commission reasonably determined that mobile broadband today is interconnected with the newly defined public switched network. It “gives subscribers the capability to communicate to . . . other users on the public switched network,” whether the recipient has an IP address, telephone number, or both. 47 C.F.R. § 20.3; see 2015 Open Internet Order, 30 FCC Rcd. at 5779–80 ¶ 391, 5785–87 ¶¶ 398–401. In contending otherwise, mobile petitioners argue that mobile broadband itself is not “interconnected with the public switched network,” 47 U.S.C. § 332(d)(2), because mobile broadband does not allow subscribers to interconnect with telephone users unless subscribers take the step of using a VoIP application. Nothing in the statute, however, compels the Commission to draw a talismanic (and elusive) distinction between (i) mobile broadband alone enabling a connection, and (ii) mobile broadband enabling a connection through use of an adjunct application such as VoIP. To the contrary, the statute grants the Commission express authority to define “interconnected service.” 47 U.S.C. § 332(d)(2). And the Commission permissibly exercised that authority to determine that—in light of the increased availability, use, and

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