59 In the 2015 Order, the Commission determined that it should expand its definition of the public switched network in that fashion to “reflect[] the current network landscape.” 30 FCC Rcd. at 5779 ¶ 391; see id. at 5786 ¶ 399. The Commission took note of “evidence of the extensive changes that have occurred in the mobile marketplace.” Id. at 5785– 86 ¶ 398. For instance, as of the end of 2014, nearly threequarters “of the entire U.S. age 13+ population was communicating with smart phones,” and “by 2019,” according to one forecast, “North America will have nearly 90% of its installed base[] converted to smart devices and connections.” Id. at 5785 ¶ 398. In addition, the Commission noted that the “hundreds of millions of consumers” who already “use[d] mobile broadband” as of 2015 could “send or receive communications to or from anywhere in the nation, whether connected with other mobile broadband subscribers, fixed broadband subscribers, or the hundreds of millions of websites available to them over the Internet.” Id. Those significant developments, the Commission found, “demonstrate[] the ubiquity and wide scale use of mobile broadband Internet access service today.” Id. at 5786 ¶ 398. The upshot is that, just as mobile voice (i.e., cellular telephone) service in 1994 provided “ubiquitous access” for members of the public to communicate with one another “from anywhere in the nation,” mobile broadband by 2015 had come to provide the same sort of ubiquitous access. Id. at 5779–80 ¶ 391, 5785–86 ¶¶ 398–99. And the ubiquitous access characterizing both mobile voice and mobile broadband stands in marked contrast to “the private mobile service[s] of 1994, such as a private taxi dispatch service, services that offered users access to a discrete and limited set of endpoints.” Id. at 5789 ¶ 404; see 1994 Order, 9 FCC Rcd. at 1414 ¶ 4. In recognition of the similarity of mobile broadband to mobile voice as a universal medium of

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