98 select, access, and use broadband Internet access service or the lawful Internet content, applications, services, or devices of their choice, or (ii) edge providers’ ability to make lawful content, applications, services, or devices available to end users.” 2015 Open Internet Order, 30 FCC Rcd. at 5660 ¶ 136. The Commission adopted the General Conduct Rule based on a determination that the three bright-line rules— barring blocking, throttling, and paid prioritization—were, on their own, insufficient “to protect the open nature of the Internet.” Id. at 5659–60 ¶¶ 135–36. Because “there may exist other current or future practices that cause the type of harms [the] rules are intended to address,” the Commission thought it “necessary” to establish a more general, nounreasonable interference/disadvantage standard. Id. The standard is designed to be flexible so as to address unforeseen practices and prevent circumvention of the bright-line rules. The Commission will evaluate conduct under the General Conduct Rule on a case-by-case basis, taking into account a “non-exhaustive” list of seven factors. Id. at 5661 ¶ 138. Before examining the merits of the vagueness challenge, we first address US Telecom’s argument that the NPRM provided inadequate notice that the Commission would issue a General Conduct Rule of this kind. Although the Commission did not ultimately adopt the “commercially reasonable” standard proposed in the NPRM, the Commission specifically sought “comment on whether [it] should adopt a different rule to govern broadband providers’ practices to protect and promote Internet openness.” NPRM, 29 FCC Rcd. at 5604 ¶ 121. The NPRM further asked: “How can the Commission ensure that the rule it adopts sufficiently protects against harms to the open Internet, including broadband providers’ incentives to disadvantage edge providers or classes of edge providers in ways that would harm Internet openness? Should the Commission adopt a rule that prohibits