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communication for the general public—and the dissimilarity
of mobile broadband to closed private networks such as those
used by taxi companies or local police and fire departments—
the Commission in 2015 sought to reclassify “today’s broadly
available mobile broadband” service as a commercial mobile
service like mobile voice, rather than as a private mobile
service like those employed by closed police or fire
department networks. 2015 Open Internet Order, 30 FCC
Rcd. at 5786 ¶ 399; see 1994 Order, 9 FCC Rcd. at 1414 ¶ 4.
Aligning mobile broadband with mobile voice based on their
affording similarly ubiquitous access, moreover, was in
keeping with Congress’s objective in establishing a defined
category of “commercial mobile services” subject to common
carrier treatment: to “creat[e] regulatory symmetry among
similar mobile services.” 1994 Order, 9 FCC Rcd. at 1413
¶ 2; see 2015 Open Internet Order, 30 FCC Rcd. at 5786
¶ 399; H.R. Rep. No. 103-111 at 259 (May 25, 1993) (noting
that amendments to section 332 were intended to ensure “that
services that provide equivalent mobile services are regulated
in the same manner”).
In the interest of achieving that regulatory symmetry and
bringing mobile broadband into alignment with mobile voice
as a commercial mobile service, the Commission updated its
definition of the “public switched network” to include both
users reachable by ten-digit phone numbers and users
reachable by IP addresses. See 2015 Open Internet Order, 30
FCC Rcd. at 5779 ¶ 391. The newly expanded definition of
“public switched network” thus covers “the network that
includes any common carrier switched network . . . that use[s]
the North American Numbering Plan, or public IP addresses,
in connection with the provision of switched services.” Id.
(emphasis added) (alteration in original); 47 C.F.R. § 20.3;
see Bell Atlantic Telephone Cos. v. FCC, 206 F.3d 1, 4 (D.C.
Cir. 2000) (“[T]he internet is a ‘distributed packet-switched
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