On December 14, 2017, the Commission voted 3-2 as expected along party lines to adopt the Internet Freedom Order that had been circulated as a draft on November 22, 2017. When effective, the new order will reverse the Commission’s 2015 Open Internet Order. Based on the Commissioners’ comments at the open meeting the new order should be substantially the same as the draft analyzed in our November 30, 2017 advisory, with one exception: Commissioner O’Rielly had asked to remove references to Title III in the discussion of the authority for adopting transparency requirements for wireless ISPs. At the meeting Commissioner O’Rielly said “I do not believe that the provisions of title three cited in the circulated version of the order should be invoked. I am relieved they have been removed from the item at my request.” In addition, in the week before the meeting the FCC announced it was signing an MOU with the FTC for ISP privacy enforcement so the order may be amended to reflect that. Accordingly there may be some time from today’s vote until final text is released. We will provide a further update at that time.