The Federal Communications Commission (FCC) has proposed classifying Broadband Internet Access (BIAS) providers under Title II of the Communications Act. The NPRM notes, correctly, that the Covid-19 pandemic highlighted the importance of broadband connections to the economy and society writ large. The Commission, however, draws the wrong conclusion from this experience. The nation’s experience with broadband, including through the pandemic, does not support the Commission’s proposal. In these comments we explain why Title II classification is unnecessary and potentially harmful.