Opinion for the court filed by Circuit Judge KAREN LeCRAFT HENDERSON.
KAREN LECRAFT HENDERSON, Circuit Judge:
The petitioner, Small Business in Telecommunications (SBT), seeks to challenge rulemaking orders of the Federal Communications Commission (FCC or Commission) that, inter alia, devised service and competitive bidding rules as well as technical and operational rules for 800 MHz Specialized Mobile Radio (SMR) service.
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