99 unreasonable discrimination and, if so, what legal authority and theories should we rely upon to do so?” Id. In light of those questions, US Telecom was on notice that the Commission might adopt a different standard to effectuate its goal of protecting internet openness. US Telecom contends that the NPRM was nonetheless inadequate because general notice of the possible adoption of a new standard, without notice about the rule’s content, is insufficient. But the NPRM described in significant detail the factors that would animate a new standard. See, e.g., id. at 5605–06 ¶¶ 124–126; id. at 5607 ¶¶ 129–31; id. at 5608 ¶ 134. The factors that are to guide application of the General Conduct Rule significantly resemble those identified in the NPRM. See 2015 Open Internet Order, 30 FCC Rcd. at 5661–64 ¶¶ 139–45. The Rule also adopted the “case-bycase,” “totality of the circumstances” approach proposed in the NPRM. 29 FCC Rcd. at 5604 ¶ 122. By making clear that the Commission was considering establishment of a general standard and providing indication of its content, the NPRM offered adequate notice under the APA. Moving to the substance of US Telecom’s vagueness argument, we note initially that it comes to us as a facial challenge. Traditionally, a petitioner could succeed on such a claim “only if the enactment [wa]s impermissibly vague in all of its applications.” Village of Hoffman Estates v. Flipside, Hoffman Estates, Inc., 455 U.S. 489, 495 (1982). That high bar was grounded in the understanding that a “plaintiff who engages in some conduct that is clearly proscribed cannot complain of the vagueness of the law as applied to the conduct of others.” Holder v. Humanitarian Law Project, 561 U.S. 1, 18–19 (2010) (internal quotation marks omitted). More recently, however, in Johnson v. United States, 135 S. Ct. 2551 (2015), the Supreme Court suggested some