80 issues surrounding the redefinition of public switched network. See AT&T 2/13 Letter at 1 (noting a meeting with representatives from Commissioners O’Rielly’s and Pai’s offices on February 11, 2015); CTIA 1/14 Letter at 1 (noting a meeting with representatives from Commissioner Pai’s office on January 12, 2015); CTIA 12/22 Letter at 1 (noting a meeting with representatives from the Commission’s General Counsel’s office and representatives from the Wireless Telecommunications Bureau on December 18, 2014); CTIA 10/17 Letter at 1 (noting a meeting with the Commission’s General Counsel and a representative from the Wireline Competition Bureau on October 15, 2014). Thus, even if the redefinition of public switched network was a “novel proposal” by Vonage during the comment period, it is clear from mobile petitioners’ own letters that they had actual notice that the Commission was considering adoption of that proposal. See National Mining Ass’n v. Mine Safety & Health Administration, 116 F.3d 520, 531–32 (D.C. Cir. 1997). In addition, in those letters, letters from others supporting mobile petitioners’ views, and responsive letters from groups like New America’s Open Technology Institute and Public Knowledge, mobile petitioners engaged in a detailed, substantive back-and-forth about the precise issues they challenge here. Reclassification of mobile broadband and redefinition of the public switched network were the focal points of that discussion, in which petitioners exchanged arguments about technology and policy with the groups supporting a broader definition of the public switched network. See Letters from CTIA and AT&T, supra; Letter from Michael Calabrese, Open Technology Institute, to Marlene H. Dortch, FCC, GN Dkt. Nos. 14-28 & 10-127 (Jan. 27, 2015); Letter from Harold Feld, Public Knowledge, to Marlene H. Dortch, FCC, GN Dkt. Nos. 14-28 & 10-127 (Jan. 15, 2015); Letter from William H. Johnson, Verizon, to