43 § 706 without reclassifying broadband.” US Telecom Pet’rs’ Br. 54 (internal citations omitted). But the Commission did not believe it could do so. Specifically, the Commission found it necessary to establish three bright-line rules, the antiblocking, anti-throttling, and anti-paid-prioritization rules, 2015 Open Internet Order, 30 FCC Rcd. at 5607 ¶ 14, all of which impose per se common carrier obligations by requiring broadband providers to offer indiscriminate service to edge providers, see Verizon, 740 F.3d at 651–52. “[I]n light of Verizon,” the Commission explained, “absent a classification of broadband providers as providing a ‘telecommunications service,’ the Commission could only rely on section 706 to put in place open Internet protections that steered clear of regulating broadband providers as common carriers per se.” 2015 Open Internet Order, 30 FCC Rcd. at 5614 ¶ 42. This, in our view, represents a perfectly “good reason” for the Commission’s change in position. Raising an additional argument, US Telecom asserts that reclassification “will undermine” investment in broadband. US Telecom Pet’rs’ Br. 54. The partial dissent agrees, pointing specifically to 47 U.S.C. § 207, which subjects Title II common carriers to private complaints. Concurring & Dissenting Op. at 24. The Commission, however, reached a different conclusion with respect to reclassification’s impact on broadband investment. It found that “Internet traffic is expected to grow substantially in the coming years,” driving investment, 2015 Open Internet Order, 30 FCC Rcd. at 5792 ¶ 412; that Title II regulation had not stifled investment when applied in other circumstances, id. at 5793–94 ¶ 414; and that “major infrastructure providers have indicated that they will in fact continue to invest under the [Title II] framework,” id. at 5795 ¶ 416. In any event, the Commission found that the virtuous cycle—spurred by the open internet rules—provides an ample counterweight, in that any harmful effects on

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