This makes sense to me. The definition is slightly awkward, but awkward in a way that preserves the FCC's ability to regulate the issue at all. If you clean up

This makes sense to me. The definition is slightly awkward, but awkward in a way that preserves the FCC's ability to regulate the issue at all. If you clean up the definition, you can get to a more coherent definition of IoT device, but without the FCC's ability to regulate the devices. I think the broader definition would probably just fall back to the FTC, and as far as consumer protection goes I think they've been asleep at the switch for decades.