Before JOLLY, SMITH, and STEWART, Circuit Judges. JERRY E. SMITH, Circuit Judge: In this multidistrict litigation case, interexchange carriers (“IXCs”) Sprint Communications Company L.P. (“Sprint”) and MCI Communications when LECs provide IXCs with services that enable the IXCs to exchange wireless-to-wireline calls that originate and terminate within the same Major Trading Area (“MTA”)? Services, Inc. / Verizon Select Services Inc. (“Verizon”) sued hundreds of local exchange carriers (“LECs”)in courts throughout the United States. Each case presents the following question: Can LECs assess IXCs access charges[1] when LECs provide IXCs with services that enable the IXCs to exchange wireless-to-wireline[2] calls that originate and terminate within the same Major Trading Area (“MTA”)? Answering in the affirmative, the district court (1) dismissed Sprint and Verizon’s claims against the LECs and (2) granted summary judgment to the LECs on their claims against Sprint, Verizon, and Level 3 Communications Co. (“Level 3″). We affirm in major part, vacate in minor part, and remand. I. The facts aren’t in dispute. Instead, this appeal centers on their legal consequences under the somewhat convoluted federal regulatory framework. A. Three types of “carriers” provide telephone service: (1) LECs, (2) IXCs, and (3) commercial mobile radio service (“CMRS”)providers. LECs provide wireline service within “a given geographical calling area”—called an “exchange area”—via networks of wires and switching equipment. Alenco Commc’ns, Inc. v. FCC, 201F.3d608, 617(5th Cir.2000). IXCs provide service “connecting callers served by different LEC[s]“or connecting CMRS providers and LECs that don’t directly interconnect. Id. CMRS providers furnish wireless service, which enables[3] to call both cellular and wireline phones. Both LECs and CMRS providers can “originate” (i.e., initiate a call placed by an end-user) and “terminate” (i.e., deliver a call to the called end-user) telecommunications traffic. IXCs, on the other hand, don’t directly connect to end-users; they only carry traffic that was originated by either a LEC or a CMRS provider.[4] Because each type of carrier connects directly with only one (if any) type of customer, the carriers must cooperate to exchange telecommunications traffic. “Intercarrier compensation comes into play whenever two or more carriers collaborate to complete a phone call.”Glob. Naps, Inc. v. Verizon NewEng., Inc., 444 F.3d 59, 63 (1st Cir. 2006). Carriers generally compensate each other in two ways: “(1)access charges; and (2) reciprocal compensation.”In re Connect Am. Fund, 26 F.C.C. Rcd. 4554, 4707 502 (2011).What sort of compensation may be assessed, and by whom, “depend[s] on a number of factors,” such as “where the call begins and ends,” “what types of carriers are involved,” and “the type of traffic” exchanged. Id. LECs impose access charges on other carriers—most commonly IXCs—for the right to access their networks and switching equipment. See Alenco, 201 F.3d at 618.LECs provide those access services using Feature Group D(“FGD”) trunks,[5] which Sprint and Verizon utilized to connect and carry the traffic at issue. Carriers can procure those services “in one of two ways: (1) by ‘affirmatively’ ordering . . .or (2) by constructively ordering” them.[6] Access charges are set by tariffs filed with the FCC and state agencies,[7] both of which actively regulate the rates that LECs can charge.[8] Historically, “access charges [we]re set relatively high in order to cover certain loop costs not recovered through local rates.”In re Fed.-State Joint Bd. on Universal Serv., 12 F.C.C. Rcd. 8776, 8784 11 (1997). Reciprocal compensation, one the other hand, was first introduced by the Telecommunications Act of 1996, Pub. L. No. 104–104, 110 Stat. 56 (codified, as amended, in scattered sections of title 47, U.S. Code) (the “1996 Act”).That compensation framework is “best understood as an ‘originator pays’ rule”: “[W]hen a customer of Carrier A places a local call to a customer of Carrier B, Carrier A must pay Carrier B for terminating the call, and vice versa.”AT&T Corp. v. Core Commc’ns, Inc., 806 F.3d 715, 719 (3d Cir. 2015).Reciprocal compensation rates are set by state-approved “interconnection agreements,” which are the product of either “voluntary negotiation or compulsory arbitration.” Sw. Bell Tel. Co. v. Pub. Util. Comm’n of Tex., 208 F.3d 475, 479 (5th Cir. 2000). Unlike access charges, reciprocal compensation is “based solely on the costs of transport and termination incurred by the terminating provider.” Atlas Tel. Co. v. Okla. Corp. Comm’n, 400 F.3d 1256, 1261 (10th Cir. 2005). The FCC and state regulators have painted with a broad brush, establishing a “bifurcated local/long-distance system for” sharing compensation between and among carriers. Alma Commc’ns Co. v. Mo. Pub. Serv. Comm’n, 490 F.3d 619, 620 (8th Cir. 2007). Generally, reciprocal compensation applies to “local” traffic, whereas access charges apply to “long-distance” traffic. See id. at 621. That legal framework applies straightforwardly for wireline-to-wireline calls, but it’s more complex for wireless-to-wireline calls. For wireline-to-wireline, state regulators enjoy the power “to determine what geographic areas should be considered ‘local areas’ . . . .” In re Implementation of the Local Competition Provisions in the Telecomms. Act of 1996 (Local Competition Order), 11 F.C.C. Rcd. 15499, 16013 1035 (1996). States generally have defined “local areas” in terms of “exchange areas,” which are relatively small geographically and often comprise “a city and its environs.” Sw. Bell Tel. Co. v. Pub. Util. Comm’n of Tex., 348 F.3d 482, 485 n.4 (5th Cir. 2003). Wireline-to-wireline calls exchanged between end-users within the same exchange area (“intraexchange”) are considered local, while calls exchanged between end-users in different exchange areas (“interexchange”) are long-distance. Intraexchange calls involve, at most, two carriers: the originating LEC and the terminating LEC (if different). See Alma, 490 F.3d at 620–21. Conversely, interexchange traffic generally involves three carriers: (1) the originating LEC, (2) an IXC to carry the call between the exchange areas, and (3) a terminating LEC. See id. at 621. Wireline end-users select both their LEC and their IXC and have separate billing relationships with each. See id. But for wireless-to-wireline traffic—that is, calls originating or terminating on CMRS networks—the FCC has the exclusive power to “define the local service area . . . .”Local Competition Order, 11 F.C.C. Rcd. at 16014 1036. Exercising that power, the FCC has determined that the MTA is the “most appropriate definition for local service area for CMRS traffic for purposes of reciprocal compensation.. . .”Id. MTAs ordinarily are much larger than exchange are as and sometimes cross state lines.[9] Calls exchanged between end-users in the same MTA (“intraMTA”) are local, and calls exchanged between end-users in different MTAs (“interMTA”) are long-distance. IntraMTA traffic can pose special problems, however. CMRS providers can exchange calls straight with LECs if they directly interconnect, and reciprocal compensation governs compensation between the carriers in that situation. See id. But sometimes CMRS providers interconnect with LECs only indirectly, through a third party (such as an IXC), presumably because it is more cost-efficient to do so.[10] That situation creates a special problem under Congress’s and the FCC’s regulatory regime, because, unlike most other local traffic, it involves three carriers instead of two. It’s also not obvious what is the relevant “local area” once an IXC is involved. Those calls are, in some sense, both intra MTA and interexchange,i.e., both local and long-distance. B. This dispute boils down to a disagreement about what compensation LECs can collect for intraMTA wireless-to-wireline calls carried by an IXC. Sprint, Verizon, and Level 3 believe that only reciprocal compensation is due, which would mean that they aren’t required to pay LECs access charges for those calls. The LECs believe that both compensation regimes apply: Reciprocal compensation is owed between CMRS providers and LECs, and access charges are owed by IXCs to LECs. Both before and after the 1996 Act, the LECs have assessed IXCs access charges for that traffic. For almost two decades after the 1996 Act was passed, Sprint and Verizon paid the LECs’ tariffed access charges without dispute. That all changed in 2014 when Sprint and Verizon sued numerous LECs across the United States. Believing that they had been systematically assessed access charges that they didn’t owe, Sprint and Verizon asserted (1) claims under 47 U.S.C. §§ 206 and 207 and (2) state-law breach of contract claims related to the LECs’ published tariffs.[11] They sought damages, in the form of refunds for access charges they’d already paid, as well as a declaratory judgment stating that they didn’t owe access charges on intraMTA wireless-to-wireline traffic going forward. Under 28 U.S.C. § 1407, the Judicial Panel on Multidistrict Litigation consolidated the actions and transferred them to the court a quo for pretrial proceedings. See In re: IntraMTA Switched Access Charges Litig., 67 F. Supp. 3d 1378 (J.P.M.L. 2014). The LECs jointly moved to dismiss. The district court granted the motion as to Sprint and Verizon’s federal-law claims, holding that (1) no stat-ute or FCC regulation had “explicitly superseded” the LECs’ pre-1996 practice of charging IXCs access charges for intraMTA wireless-to-wireline calls and (2) the filed-rate doctrine therefore barred the refunds. The court dismissed Sprint and Verizon’s state-law claims, because (1) intrastate access charges were permissible under federal law, (2) Sprint and Verizon hadn’t identified any state law that prohibited the charges, and (3) they hadn’t alleged that the access charges violated tariffs filed with state authorities. The district court offered those companies an opportunity to replead their state-law claims, and Sprint (but not Verizon) did so. Shortly thereafter, the LECs moved to dismiss Sprint’s amended complaints. The court again dis-missed, finding that Sprint had “failed to plausibly allege either a state law or a specific state tariff that prohibit[ed] LECs from charging IXCs access charges on intrastate intraMTA calls.” After the claims against them were dismissed, many (but not all) of the LECs filed counterclaims against Sprint and Verizon. Several LECs also filed new claims against Level 3. Collectively, those claims sought to recover unpaid and late access charges.[12] Level 3 moved to dismiss the claims against it, but the court denied that motion for essentially the same reasons it granted the LECs’ motion to dismiss. The LECs then moved for summary judgment on all of their claims. After reviewing the parties’ stipulations regarding the access charges owed, the court granted summary judgment to the LECs. Sprint, Verizon, and Level 3 appeal.[13] II. Sprint and Verizon’s claims span several regulatory regimes, so it’s necessary to canvas the history of American telecommunications regulation. A. Before 1984, American Telephone & Telegraph Company (“AT&T”) held a near-national monopoly on local wireline telephone service through its Bell Operating Companies (“BOCs”). See United States v. Am. Tel. & Tel. Co. (Modification of Final Judgment), 552 F. Supp. 131, 139 n.19 (D.D.C. 1982). In response to the DOJ’s landmark 1974 antitrust suit, however, the government and AT&T proposed a consent decree that made “significant structural changes” to AT&T. Id. at 141. Chief among those modifications was AT&T’s agreement to divest its LECs. Id. That divestiture effectively created a LEC market characterized by a system of government-sanctioned “regional service monopolies,” colloquially known as “‘Regional [BOCs],’ ‘Baby Bells,’ or ‘Incumbent Local Exchange Carriers’ (ILECs).” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 549 (2007). Each LEC could connect and carry intraexchange wireline-to-wireline calls without having to cooperate with any other carriers.[14] Another consequence of the divestiture was a separate, competitive mar-ket for interexchange wireline service from which the LECs were excluded. See id. IXCs connected and carried calls between LECs and paid “access charges” to both the originating and terminating LEC for the right to connect to their exchange networks. See Modification of Final Judgment, 552 F. Supp. at 169. The Modification of Final Judgment provided some baseline terminology that the FCC later adopted.[15] For example, it defined “exchange access” to mean “the provision of exchange services for the purpose of originating or terminating interexchange telecommunications.” Id. at 228.Relatedly, “ex-change access services include[d]any activity or function performed by a BOC in connection with the origination or termination of interexchange telecommunications.”[16] And “[e]xchange area” was defined, in relevant part, as a “geographic area established by a BOC.. . [consisting of] one or more contiguous local exchange areas serving common social, economic, and other purposes….”[17] After the divestiture was completed in 1984, the FCC adopted regulations governing exchange access services and access charges. See47 C.F.R.§§69.1etseq. (1984).The FCC defined “[a]ccessservice[s]” to include “ services and facilities provided for the origination or termination of any interstate or foreign telecommunication.”Id. §69.2(b)(emphasis added). The regulations also provided that “carrier charges,” including access charges, “shall be computed and assessed upon all [IXCs] that use local exchange switching facilities for the provision of interstate or foreign telecommunications services.”Id. § 69.5(b). The LECs had to file tariffs for their access charges with the FCC. See id. §§ 69.3, 69.4. B. In 1996, Congress rejected that monopoly-focused regime and “fundamentally change[d] telecommunications regulation.” Local Competition Order, 11 F.C.C. Rcd. at 15505 1. The 1996 Act ushered in a new system meant to “remove the outdated barriers that protect monopolies from competition and affirmatively promote efficient competition . . . .” Id. The 1996 Act began by carrying forward several statutory terms from the Communications Act of 1934, Pub. L. No. 73–416, 48 Stat. 1064 (codified, as amended, in scattered sections of title 47, U.S. Code) (the “1934 Act”). One is particularly relevant: “telephone toll service,” which referred to “telephone service between stations in different exchange areas for which there is made a separate charge not included in contracts with subscribers for exchange ser-vice.”[18] The 1996 Act also introduced two new terms: “exchange access” and “local exchange carrier.” It defined “exchange access” as “the offering of access to telephone exchange services or facilities for the purpose of the origination or termination of telephone toll services.” 47 U.S.C. § 153(16) (Supp. 1997). Relatedly, “local exchange carrier” meant “any person that is engaged in the pro-vision of telephone exchange service or exchange access.” Id. § 153(26). Each of those statutory definitions, though renumbered, remains unchanged.[19] Critically, the 1996 Act didn’t devise any definitions for traffic exchanged between wireless and wireline phones. To effect the1996 Act’s purpose, Congress took two steps. First, to remove barriers to competition in the market for local telecommunications services, Congress provided that “[n]o State or local statute or regulation. . .may prohibit or have the effect of prohibiting the ability of any entity to provide any interstate or intrastate telecommunications service.”Id. §253(a). And second, to increase competition, Congress enacted §251, which “impose[d] three tiers of duties on three different, statutorily defined categories of telecommunications-related entities. . . .”Pac. Bell v. Cook Telecom, Inc., 197 F.3d 1236,1237 (9th Cir. 1999). Most pertinently,§251 imposes two duties on LECs. First, they have a duty “to interconnect directly or indirectly with the facilities and equipment of other telecommunications carriers.”[20] Second, LECs have an affirmative “duty to establish reciprocal compensation arrangements for the transport and termination of telecommunications.”[21] Under the old local-monopoly framework, the same LEC would originate, carry, and terminate all calls within its ex-change area. But on account of new LEC market entrants, end-users in the same exchange area often subscribed to different LECs. Under reciprocal compensation, the originating LEC pays the terminating LEC a fee reasonably approximating the costs of terminating the call. See 47 U.S.C. § 252(d)(2)(A)(ii) (Supp. 1997). Given the significant changes Congress made to telecommunications regulation, it also took steps to facilitate a transition for carriers. To avoid upset-ting settled compensation practices, at least until the FCC stepped in to regulate,[22] Congress included a clause temporarily preserving the status quo: On and after February 8, 1996, each [LEC], to the extent that it provides wireline services, shall provide exchange access, information access, and exchange services for such access to [IXCs] and information service providers in accordance with the same equal access and nondiscriminatory interconnection restrictions and obligations (including receipt of compensation) that apply to such carrier on the date immediately preceding February 8, 1996, under any court order, consent decree, or regulation, order, or policy of the Commission, until such restrictions and obligations are explicitly superseded by regulations prescribed by the Commission after February 8, 1996. During the period beginning on February 8, 1996, and until such restrictions and obligations are so superseded, such restrictions and obligations shall be enforceable in the same manner as regulations of the Commission. Id. § 251(g) (emphasis added). Put plainly, the 1996 Act grandfathered in the pre-1996 compensation frameworks—including the access charge regulations—until the FCC explicitly superseded them. See CenturyTel of Chatham, LLC v. Sprint Commc’ns Co., 861 F.3d 566, 570 (5th Cir. 2017). C. On August 8, 1996, the FCC issued an order implementing the 1996 Act’s local-competition provisions. See generally Local Competition Order, 11 F.C.C. Rcd. 15499. The FCC issued significant guidance about §251(b)(5)’s reciprocal compensation regime, but it led with a big caveat: “Nothing in this Report and Order alters the collection of access charges paid by an [IXC]under Part 69of the [FCC]‘s rules. . ..”[23] Importantly, the FCC wasn’t supplanting its pre-Act access charge regulations. Although the Local Competition Order spills a lot of ink, the bulk of the Order that is relevant to this dispute relates to what is colloquially called the “IntraMTA Rule.” That Rule outlines the relationship under §251(b)(5) between LECs and CMRS providers. Though the Order alludes to IXCs’ place within that framework, it doesn’t focus on IXCs. Before evaluating what obligations LECs and CMRS providers owed to one another, the FCC first resolved how CMRS providers fit within the regulatory framework. The FCC made two threshold decisions. First, it declined to treat CMRS providers as LECs, even though CMRS providers could origin-ate and terminate calls within a single exchange area. Id. At 15995–96
1004, 1006. And second, the FCC found that “CMRS providers offer[ed] telecommunications,” which obligated LECs “to enter into reciprocal compensation arrangements with [them].”Id. at 15997 1008. Next, the FCC sketched out the boundaries of LECs’ duty to enter into reciprocal compensation agreements with CMRS providers. The FCC divvied all traffic into two buckets: “local” and “long distance.”Id. at 16012–13 1033.Reciprocal compensation applied “only to traffic that originate[d] and terminate[d] within a local area.” Id. at 16013 1034. Access charges, on the other hand, were “governed by sections 201 and 202,” and, as a result, by the FCC’s access charge regulations. Id. at 16013 1033. “Local area” was defined in two ways. For traffic that didn’t involve a CMRS provider, “local area” was generally defined by reference to “exchange areas.”[24] But for calls that involved a CMRS provider, the FCC determined that the MTA was “the most appropriate definition for local service area . . . .” Id. at 16014 1036. “Accordingly, traffic to or from a CMRS network that originates and terminates within the same MTA is subject to transport and termination rates under [§] 251(b)(5), rather than interstate and intrastate access charges.” Id. Conversely, for both wireline-to-wireline and wireless-to-wireline calls, “[t]raffic originating or terminating outside of the applicable local area would be subject to interstate and intrastate access charges.”[25] In reaching that conclusion, the FCC explicitly rejected the “contention that [§] 251(b)(5) entitles an IXC to receive reciprocal compensation from a LEC when a long-distance call is passed from the LEC serving the caller to the IXC.” Id. at 16013 1034. The FCC offered the following discussion as to why: Access charges were developed to address a situation in which three carriers—typically, the originating LEC, the IXC, and the terminating LEC—collaborate to complete a long-distance call. . . . By contrast, reciprocal compensation for transport and termination of calls is intended for a situation in which two carriers collaborate to complete a local call. . . . We note that our conclusion that long distance traffic is not subject to the transport and termination provisions of [§] 251 does not in any way disrupt the ability of IXCs to terminate their interstate long-distance traffic on LEC networks. Pursuant to [§] 251(g), LECs must continue to offer tariffed interstate access services just as they did prior to enactment of the 1996 Act. We find that the reciprocal compensation provisions of [§] 251(b)(5) for transport and termination of traffic do not apply to the transport or termination of interstate or intra-state interexchange traffic. Id. (emphasis added). As part of the Local Competition Order, the FCC promulgated regulations governing “reciprocal compensation for transport and termination of local telecommunications traffic between LECs and other telecommunications carriers.” 47 C.F.R. § 51.701(a) (1996). The regulations defined “[l]ocal telecommunication traffic” as (1) Telecommunications traffic between a LEC and a telecommunications carrier other than a CMRS provider that originates and terminates within a local service area established by the state com-mission; or (2) Telecommunications traffic between a LEC and a CMRS pro-vider that, at the beginning of the call, originates and terminates within the same Major Trading Area . . . . Id. § 51.701(b). Notably, those definitions speak to the nature of the traffic as well as the parties involved in originating, transporting, and terminating it. LECs weren’t permitted to “assess charges on any other telecommunications carrier for local telecommunications traffic that originate[d] on [their] net-work[s].” Id. § 51.703(b). D. A few years later, the FCC addressed “whether intercarrier compensation for ISP-bound traffic” was subject to reciprocal compensation under § 251(b)(5) or whether the existing compensation regime—”in which the originating carrier pays the carrier that serves the ISP”—was grandfathered in under § 251(g). In re Implementation of the Local Competition Provisions in the Telecomms. Act of 1996 (Intercarrier Compensation Order), 16 F.C.C. Rcd. 9151, 9153–54
