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Your points are right on the mark. I would add that imprecise definitions are a huge concern because the FCC has a history of making regulations in *conflict* with the enabling statutes that give them the rule-making capability. Two examples are the requirement for applying CALEA wiretapping requirements to broadband in spite of Congress' specific exemption of information services and the Internet, and their creation of an established business relationship exemption for prerecorded telemarketing advertisements where no such exemption exists in the Telephone Consumer Protection Act.