85 Marlene H. Dortch, FCC, GN Dkt. Nos. 14-28 & 10-127, at 1 (Feb. 3, 2015). B. Full Service Network contends that the Commission acted arbitrarily and capriciously in forbearing from the mandatory network connection and facilities unbundling requirements contained in sections 251 and 252. As relevant here, section 251 requires telecommunications carriers “to interconnect directly or indirectly” with other carriers and prohibits them from “impos[ing] unreasonable or discriminatory conditions or limitations on[] the resale of . . . telecommunications services.” 47 U.S.C. § 251(a)(1), (b)(1). “Incumbent local exchange carrier[s],” meaning carriers who “provided telephone exchange service” in a particular area as of the effective date of the Telecommunications Act, must provide nondiscriminatory access to their existing networks and unbundled access to network elements in order to allow service-level competition through resale. Id. § 251(c), (h)(1). Section 252 sets standards for contracts that implement section 251 obligations. Full Service Network first argues that section 10(a)(3)’s public interest determination “must be made for each regulation, provision and market . . . using the definition and context of that provision in the [Communications] Act.” Full Service Network Pet’rs’ Br. 14–15 (emphasis omitted). Because section 251 “applies to ‘local exchange carriers,’” Full Service Network contends, “the geographic market, as the name implies and the definition in the [Communications] Act confirms, is local and not national.” Id. at 15 (emphasis omitted) (quoting 47 U.S.C. § 251).

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