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MEMORANDUM OPINION BERYL A. HOWELL, United States District Judge The plaintiff, Pharmaceutical Research and Manufacturers of America (“PhRMA”), a trade association which “represents the country’s leading biophar-maceutical researchers and biotechnology companies,” see Compl. ¶¶ 9-10, ECF No. 1, seeks to set aside a Final Rule issued by the Federal Trade Commission (“FTC”) that requires the pharmaceutical industry to report certain transfers of exclusive patent rights under Section 7A of the Hart-Scott-Rodino Antitrust Improvements Act (“HSR Act”), 15 U.S.C. § 18a; Premerger Notification; Reporting and Waiting Period Requirements, 78 Fed.Reg. 68,705 (Nov. 15, 2013) (“Final Rule”); JtApp. (“JA”) at 7-15, ECF No. 19. PhRMA challenges the Final Rule as violative of the Administrative Procedures Act (“APA”), 5 U.S.C. § 706, because the FTC: (1) lacked statutory authority to issue an industry-specific rule rather than a rule of general application; (2) failed to establish a rational basis for such an industry-specific rule; and (3) failed to comply with legally required procedures. See Compl. ¶¶ 89-106. Pending before the Court are the parties’ cross motions for summary judgment. See PL’s Mot. Summ. J. (“Pl.’s Mot.”), ECF No. 13; Def.’s Mot. Summ. J. (“Def.’s Mot.”), ECF No. 15. For the reasons explained below, PhRMA’s motion is denied and the FTC’s motion is granted. 1. BACKGROUND The Final Rule states, and PhRMA does not dispute, that “the granting of an exclusive right to commercially use a patent or part of a patent is a potentially reportable asset acquisition under the [HSR] Act.” 78 Fed.Reg. at 68,706; JA at 8. The gravamen of PhRMA’s complaint is that the Final Rule imposes “fundamental changes to the HSR Act pre-merger notification requirements that would, for the first time in the Act’s 37-year history, single out and burden one industry alone with additional notification requirements for patent license transactions previously not regarded. by the antitrust agencies as potentially anti-competitive enough to warrant any pre-closing review whatsoever.” PL’s Mem. Pts & Authorities Supp. Mot. Summ. J. (“PL’s Mem.”) at 5, ECF No. 13. According to PhRMA, this “selective coverage,” id., exceeds the FTC’s statutory authority “to relieve certain classes of persons or transactions” from notification requirements and “[i]nstead, the Rule imposes new burdens selectively on a targeted class of persons (Le., those in the pharmaceutical industry only) in connection with patent license transactions suddenly now regarded by the agency as likely anticom-petitive,” id. at 17 (emphasis in original). Specifically, the Final Rule addresses two types of transfers of exclusive patent rights that the FTC observed occurred frequently, if not exclusively, in the pharmaceutical industry, prompting the agency to limit application of the Rule to this industry: (1) the transfer of exclusive rights under a patent to use and sell, with retention by the licensor of the right to manufacture (“retained manufacturing rights”); and (2) the transfer of exclusive rights under a patent to make, use, and sell, with retention by the licensor of co-rights, in whole or part (“retained co-rights”). 78 Fed.Reg. at 68,707-08; JA at 9-10. PhRMA contends that the “selective coverage” of the Final Rule exceeds the FTC’s authority under the plain terms of the HSR Act and, furthermore, even if the statute were found to be ambiguous, the agency’s “interpretation of its authority is completely at odds with congressional intent,” PL’s Reply Supp. Mot. Summ. J. & Opp’n FTC’s Cross-Mot. Summ. J. (“PL’s Reply”) at 1, ECF No. 17, such that the Final Rule “is entitled to no deference, and [ ] should be vacated,” id. at 18. The FTC disputes PhRMA’s view that the meaning of the HSR Act is plain, positing instead that the statute is silent regarding whether “Congress intended to prohibit the Commission from issuing industry-specific coverage rules.” Defi’s Mem. Pts. & Authorities Supp. Mot. Summ. J. & Opp’n PL’s Mot. Summ. J. (“Def.’s Mem.”) at 11, ECF No. 15. The FTC further contends that the Final Rule is an appropriate exercise of its authority to define terms used in the Act “as necessary and appropriate to carry out the purposes of’ the statute. Id. at 14. To aid in resolution of this dispute over statutory interpretation, the Court begins with an overview of the HSR Act, before turning to a discussion of the challenged rule and procedural history of the instant case. A. Statutory and Regulatory Framework Enacted in 1976, the HSR Act was intended to assist enforcement agencies in determining whether an anticipated merger or acquisition was likely to violate federal antitrust laws. See S. REP. No. 94-803, at 1 (1976); H.R. REP. NO. 94-1373, at 5 (1976), reprinted in 1976 U.S.C.C.A.N. 2637, 1976 WL 13988; Mattox v. FTC, 752 F.2d 116, 119-20 (5th Cir.1985) (finding that the HSR Act “was designed to allow review of mergers before they were completed” to determine, pre-consummation, whether such mergers violated antitrust laws). To this end, Section 7A of the HSR Act, codified in 15 U.S.C. § 18a, requires the transferring parties to report to the FTC and the Assistant Attorney General at the U.S. Department of Justice any anticipated transfers of assets when the transferred asset and/or the transferring parties meet certain minimum size requirements specified in the Act. The Act “reflects a congressional judgment that divestiture and other post-acquisition remedies were difficult, expensive and sometimes futile,” and that safeguards were therefore necessary to evaluate anticipated mergers before they occurred. Mattox, 752 F.2d at 119. Section 7A of the HSR Act provides that, when planned acquisitions meet statutorily defined minimum size requirements, “[ejxcept as exempted pursuant to subsection (c) of this section, no person shall acquire, directly or indirectly, any voting securities or assets of any other person, unless both persons ... file notification pursuant to rules under subsection (d)(1) of this section and the waiting period described in subsection (b)(1) of this section has expired.” See 15 U.S.C. § 18a(a); see also An Act to Improve and Facilitate the Expeditious and Effective Enforcement of the Antitrust Laws, And For Other Purposes, Pub. L. No. 94-435 tit. II, § 7A(a) (1976). Subsection (c) of the Act exempts altogether certain classes of transactions from the reporting requirement in subsection (a). 15 U.S.C. § 18a(c). In addition to eleven categories of statutorily defined exempt transactions, subsection (c) also authorizes the FTC to exempt from premerger notification “such other acquisitions, transfers, or transactions” that otherwise meet the minimum size requirements. See id. § 18a(c)(12). The FTC’s broad exemption authority is also repeated in subsection (d), which provides for the exercise of rulemaking and exemption authorities at issue in the instant suit. Specifically, subsection (d)(1) authorizes the FTC to promulgate rules to implement the Act, stating that the FTC “shall require that the notification required under subsection (a) of this section be in such form and contain such documentary material and information relevant to a proposed acquisition as is necessary and appropriate to enable the Federal Trade Commission and the Assistant Attorney General to determine whether such acquisition may, if consummated, violate the antitrust laws[.]” 15 U.S.C. § 18a(d)(l). Subsection (d)(2) grants the FTC authority to “define the terms used in this section” and “prescribe such other rules as may be necessary and appropriate to carry out the purposes of this section.” Id. § 18a(d)(2)(A), (C). Finally, subsection (d)(2)(B) authorizes the FTC to “exempt, from the requirements of this section, classes of persons, acquisitions, transfers, or transactions which are not likely to violate the antitrust laws[.]” Id. § 18a(d)(2)(B). Pursuant to the rulemak-ing authority granted by subsection 18a(d), the FTC has promulgated rules codified in 16 C.F.R. §§ 801-03. The Final Rule challenged in this action amended the regulation at 16 C.F.R. § 801.2. In sum, three provision in the HSR Act, subsections (a), (c), and (d), expressly authorize the FTC to exempt certain “classes of persons, acquisitions, transfers, or transactions” from the requisite reporting, even if the transfer of assets meets the minimum size requirements under subsection (a). B. Challenged FTC Rule In order to clarify the meaning of an acquiring or acquired person, used in section (a) of the HSR Act, 15 U.S.C. § 18a(a), the Final Rule adds a new paragraph (g) to 16 C.F.R. § 801.2, which sets out the criteria for transfers that are reportable under the HSR Act. 78 Fed.Reg. at 68,712-13; JA at 14-15. This new paragraph (g) clarifies that the “[transfers of patent rights within NAICS Industry Group 3254 [i.e., the pharmaceutical industry] ... constitutes an asset acquisition ... if and only if all commercially significant rights to a patent ... for any therapeutic area (or specific indication within a therapeutic area) are transferred to another entity. All commercially significant rights are transferred even if the patent holder retains limited manufacturing rights ... or co-rights.... ” 78 Fed.Reg. at 68,713; JA at 15. The Final Rule also adds and defines three new terms: “[a]ll commercially significant rights,” “[l]imit-ed manufacturing rights,” and “co-rights” to 16 C.F.R. § 801.1, which contains HSR Act definitions, 78 Fed.Reg. at 68,712-13; JA at 14-15. The rulemaking process underlying the adoption of the Final Rule is described below. 1. Notice of Proposed Rulemaking On August 20, 2012, the FTC issued a Notice of Proposed Rulemaking (“NPRM”) to clarify when “the transfer of exclusive rights to a patent in the pharmaceutical industry [for a specific therapeutic area] ... constitute^] a potentially reportable asset acquisition.” Premerger Notification; Reporting and Waiting Period Requirements, 77 Fed.Reg. 50,057, 50,058 (Aug. 20, 2012); JA at 2. The NPRM proposed a new paragraph to 16 C.F.R. § 801.2 stating that the transfer of patent rights covering products for which the manufacture and sale would generate revenues in the pharmaceutical industry, are reportable acquisitions when “[a]ll commercially significant rights” are transferred even if the patent holder retains “limited manufacturing rights” or “co-rights,” as defined in the new proposed definitions at 16 C.F.R. § 801.1(p) and (q), respectively. 77 Fed.Reg. at 50,061; JA at 5. Since the discussion in the NPRM about the proposed rule is repeated and supplemented in the Final Rule, the Court summarizes the background and rationale for the new definitions and new paragraph comprising the challenged rule in the discussion of the Final Rule. The FTC received three comments in response to the NPRM, two in support and one in opposition. JA at 16-21 (Comment 1 from Antonio Burrell, private citizen) (Oct. 25, 2012) (supporting the rule); id. at 22-68 (Comment 2 from PhRMA (“PhRMA Comment”)) (Oct. 25, 2012) (opposing the rule); and id. at 69 (Comment 3 from Clyde Dinkins, private citizen) (Aug. 13, 2012) (supporting the rule as “long overdue”). In support of its critical comment, PhRMA submitted the declaration of economic consultant Thomas R. Varner (“Varner Deck”), who was retained by PhRMA. See generally Varner Deck, JA at 38-68. After the close of the comment period on October 25, 2012, 78 Fed.Reg. at 68,706; JA at 8, PhRMA met with Commissioners on the FTC on four different occasions to discuss the proposed rule. See JA at 71 (Summary of Communications: Apr. 18, 2013 meeting between PhRMA and FTC Chairwoman Edith Ramirez and FTC staff); JA at 70 (Summary of Communications: Apr. 3, 2013 meeting between PhRMA and FTC Commissioner Joshua D. Wright and his advisers); JA at 75 (Summary of Communications: Mar. 13, 2013 meeting between PhRMA and FTC Commissioner Julie Brill and her attorney advisors and staff); JA at 77 (Summary of Communications: Feb. 26, 2013 meeting between PhRMA and FTC Commissioner Maureen K. Ohlhausen and her attorney advisors). Over the course of these meetings, PhRMA submitted “additional information about [the] projected costs” of the proposed rule, see JA at 72-74 (Letter dated June 7, 2013, from plaintiff’s counsel to an FTC Commissioner), reiterated the objections discussed in its comment to the proposed rule, and raised three additional objections: (1) the rule conflicted with international antitrust principles of nondiscrimination, id. at 70, 71, 77; (2) pharmaceutical transactions subject to the proposed rule would be easy to unwind, id. at 70, 75; and (3) the proposed rule would set a bad precedent, id. at 77. 2. The Final Rule Notwithstanding the critical views expressed by PhRMA in response to the NPRM and in meetings with FTC Commissioners, the Final Rule was promulgated without any changes from the proposed version on November 15, 2013, and became effective on December 16, 2013. 78 Fed. Reg. at 68,705; JA at 7; see also 78 Fed. Reg. at 68,706; JA at 8 (stating that “[a]f-ter carefully considering the comments,” the FTC decided to “adopt[] the rule as proposed”). The Final Rule rested on the FTC’s authority under 15 U.S.C. 18(a)(d) “to require that premerger notification be in such form and contain such information and documentary material as may be necessary and appropriate,” and “to define the terms used in the Act and prescribe such other rules as may be necessary and appropriate to carry out the purposes” of the section. 78 Fed.Reg. at 68,705-06; JA at 7-8 (citing 15 U.S.C. § 18a(d)(l), (2)). The rule “is limited to the pharmaceutical industry,” but makes clear that “to the extent [ ] other industries engage in similar exclusive licensing transactions, such transactions remain potentially reportable events under the Act,” and that the FTC continued “to assess the appropriateness of a rule for other industries.” 78 Fed. Reg. at 68,706; JA at 8 A brief review of the practice of transferring exclusive patent rights, as described in the Final Rule (and the NPRM), is helpful in understanding the context for the FTC’s action. a) Transfer of Exclusive Patent Rights As noted, while the HSR Act sets out statutory minimum threshold size requirements for reportable acquisitions, 15 U.S.C. § 18a(a), the Act also authorizes the FTC to define critical terms in order to target those transactions triggering the reporting requirement, id. § 18a(d)(2)(A). A patent is considered an asset by the FTC, the transfer of which may be reportable. 78 Fed.Reg. at 68,706 & n.4; JA at 8 & n.4 (citing SCM Corp. v. Xerox Corp., 645 F.2d 1195, 1210 (2d Cir.1981), for proposition that “[s]ince a patent is a form of property ... and thus an asset, there seems little reason to exempt patent acquisitions from scrutiny under” the HSR Act). Transactions may, however, involve the transfer of certain exclusive patent rights without transferring the patent in its entirety, which requires a more searching analysis of the nature of the rights being transferred. See id. According to the FTC, the transfer of the “right to commercially use [a] patent, or a part of [a] patent, to the exclusion of all others ... is substantively the same as buying the patent or part of the patent outright” and is “a potentially reportable asset acquisition under the Act.” Id. “For years” the Premerger Notification Office (“PNO”), the division of the FTC that administers the premerger notification program, Defi’s Mem. at 3, would evaluate whether the transfer of rights to a patent was potentially reportable by analyzing whether the exclusive rights to “make, use, and sell” under a patent were being transferred, see 78 Fed.Reg. at 68,706; JA at 8 (“[T]he PNO had only to verify that the transfer involved the exclusive right to use a patent or part of a patent to develop a product, manufacture the product, and sell that product without restriction”); see also Def.’s Mem. at 4. The FTC explained that “[a]lthough never codified, the ‘make, use and sell’ approach became well-known throughout the HSR bar and is reflected in the numerous letters and emails from practitioners in the PNO’s informal interpretation database on its Web site,” 78 Fed.Reg. at 68,706 & n.8; JA at 8 & n.8 (including in a footnote a link to the online location of the informal interpretation database). The Final Rule discussed two categories of patent rights transfers that, according to the FTC, appeared predominantly, if not exclusively, in the pharmaceutical industry. 78 Fed.Reg. at 68,707-08; JA at 9-10. The first category of transactions occurs when the licensor sells exclusive rights to use and sell a patent to a licensee, but retains for itself manufacturing rights. Id. The FTC noted that “in the pharmaceutical industry, the right to manufacture is less important than the right to commercialize,” such that transferring use and sale rights to a patent and retaining “the right to manufacture solely for the licensee ... has the same effect as a transfer to the licensee of all patent rights” under the “make, use, and sell” approach. 78 Fed.Reg. at 68,708; JA at 10. The second category of transactions occurs when the licensor retains co-rights, which are “shared rights to assist the licensee in developing and commercializing the patented product and includes rights to co-develop, co-promote, co-market, and co-commercialize,” even though the licensor has already granted the licensee “an exclusive license to ‘make, use, and sell’ under a patent.” 78 Fed.Reg. at 68,707; JA at 9. Under such agreements, the licensor does not retain the right “to commercially use the patent or part of the patent” and, consequently, even under the “make, use, and sell” approach, such transaction is potentially reportable under “the PNO staff’s established position.” Id. These two categories of patent rights transfers, where the licensor retains only manufacturing rights or co-rights, are the subject of the FTC’s Final Rule. b) Need for Proposed Rule According to the FTC, transfers of exclusive patent rights covered by the Final Rule “carrfy] the same potential anticom-petitive effects” as buying a patent outright. 78 Fed.Reg. at 68,706; JA at 8; see also 78 Fed.Reg. at 68,709; JA at 11 (transfers of patent rights subject to the Final Rule “are functionally equivalent to patent transfers and are thus properly viewed as asset acquisitions under the Act”); 78 Fed.Reg. at 68,711; JA at 13 (“Like patent sales, exclusive patent licenses prevalent in the pharmaceutical industry are asset acquisitions that may produce anticompetitive effects.”). Further, in the FTC’s view, “[allowing such transactions to go unreported would deprive the Commission of an opportunity, consistent with the purpose of the Act, to review these significant asset acquisitions that, like other reportable asset acquisitions, are potentially anticompetitive.” 78 Fed.Reg. at 68,709; JA at 11. Consequently, the Final Rule adopts the “all commercially significant rights” concept to determine whether the exclusive rights to a patent are an “asset” subject to reporting under the Act, as proposed in the NPRM. 78 Fed.Reg. at 68,707; JA at 9; see also 77 Fed.Reg. at 50,059; JA at 3. The FTC pointed out that the test for “ ‘ all commercially significant rights’ ” adopted in the rule “captures more completely what the ‘make, use, and sell’ approach was a proxy for, namely whether the license has transferred the exclusive right to commercially use a patent or a part of a patent.” 78 Fed.Reg. at 68,707; JA at 9. The FTC stated that “the amended reporting requirements are necessary to effectuate the purposes of the HSR Act,” which “is intended to allow the Agencies to review significant transactions to determine, prior to consummation of a transaction, if it is anticompetitive.” 78 Fed.Reg. at 68,711; JA at 13. The FTC clarified that the rule only codified “the PNO’s long-standing position that the retention of co-rights does not render a license to the patent or part of the patent as non-exclusive,” and explained that “a reportable asset transfer may occur even if the licensor retains the limited right to manufacture under the patent or part of a patent for the licensee.” 78 Fed.Reg. 68,-707; JA at 9; see also id. (“[W]ith the exception of the treatment of the right to manufacture exclusively for the licensee, the rule treats the reportability of exclusive licensing arrangements, including those where the licensor retains co-rights, in the same way that the PNO has for decades.”). c) Justification for Limiting Rule to the Pharmaceutical Industry The FTC limited the Final Rule to the pharmaceutical industry based upon the following four findings: First, “exclusive patent licensing agreements that transfer all of the rights to commercially use a patent or part of a patent almost solely occur in the pharmaceutical industry.” 78 Fed. Reg. at 68,708; JA at 10; see also id. (“[T]he PNO typically does not see exclusive transfers of rights to a patent or part of a patent outside the pharmaceutical context, and this is likely a result of the incentives that characterize the industry.”). Second, the use of this transfer mechanism in the pharmaceutical industry is growing. 78 Fed.Reg. at 68,706; JA at 8 (“In recent years ... it has become more common for pharmaceutical companies to transfer most but not all of the rights to ‘make, use and sell’ under an exclusive license, such that [this] approach is no longer adequate in evaluating the reporta-bility of exclusive licenses in the pharmaceutical industry for HSR purposes.”); see also 78 Fed.Reg. at 68,707; JA at 9 (“[D]ue to the evolution of pharmaceutical patent licenses, the ‘make, use, and sell’ approach is no longer adequate to evaluate the HSR reportability of exclusive patent licenses in the pharmaceutical industry.”). Third, according to the FTC, transfers of exclusive patent rights in the pharmaceutical industry operate differently as compared to other industries. 78 Fed. Reg. at 68,708; JA at 10. As explained in the Final Rule, a licensor typically grants exclusive patent rights to a licensee in exchange for the requisite resources and funding to complete the FDA approval process, whereas in other industries, the sale of a patent comes “at a much later stage in development, and the patent owner can simply sell the patent for its proven value.” Id. Further, outside the pharmaceutical industry, licensors are typically incentivized to “engag[e] as many licensees as possible,” rather than to grant exclusive licenses, as in the pharmaceutical industry. Id. The FTC explained that it reached this conclusion “[biased on HSR filings and requests for advice on the reportability of transactions,” id., noting that the FTC found that “[practitioners who represent clients in the pharmaceutical industry have often sought guidance from the PNO about” the acquisitions covered by the Final Rule, 78 Fed.Reg. at 68,706; JA at 8. Consequently, the Final Rule was limited to the pharmaceutical industry because “this is where the need for clarification arises and where the Commission has experience with the relevant transactions.” 78 Fed.Reg. at 68,708; JA at 10. The Final Rule elaborated that, since 2008, the PNO received filings for 66 transactions involving exclusive patent licenses, and all were for pharmaceutical patents. The PNO has not found other industries that rely on these types of arrangements. Although it is possible for other industries to engage in the kind of exclusive licensing that typifies the pharmaceutical industry, the PNO has not processed filings related to these kinds of exclusive licenses in any other industry in the past five years. In addition, requests for guidance on the treatment of exclusive patent licensing transactions have generally been limited to the pharmaceutical industry. Accordingly, the Commission has not found a need for a rule applicable to other industries. Id. (emphasis added). The Final Rule reiterated the points made in the NPRM that the rule would “address the evolving structure of exclusive patent licenses in the pharmaceutical industry, [and] provide[ ] the Agencies with a more effective means of reviewing exclusive patent licenses meeting the statutory requirements under the Act.” 78 Fed.Reg. at 68,707; JA at 9. Finally, the FTC limited the new rule to one industry because it “need not take an all-or-nothing approach ... [but] may proceed incrementally” in promulgating regulations and “may limit rules to those areas where [it has] observed a problem to be addressed.” 78 Fed.Reg. at 68,709-10; JA at 11-12. The FTC believed it was “not required to resolve a problem that may occur more broadly ‘in one fell regulatory swoop’ ” but will, instead, “continue to assess the appropriateness of a rule for other industries.” 78 Fed.Reg. 68,710; JA at 12. d) Consideration and Rejection of PhRMA’s Objections Throughout the Final Rule, the FTC addressed the objections PhRMA raised in its comment to the NPRM. See generally 78 Fed.Reg. at 68,705-13; JA at 7-15. Specifically, PhRMA criticized the proposed rule for three significant perceived shortcomings, none of which were determined by the FTC to warrant modification or rejection of the rule as proposed in the NPRM. i. Objection to Treatment of Retained Co-Rights First, PhRMA objected to the PNO’s uniform treatment of the retention of co-rights as “unclear and/or inconsistent,” because it failed to “differentiate between the kinds, magnitude, or scope of co-rights being retained,” as required under the HSR Act. 78 Fed.Reg. at 68,707; JA at 9. PhRMA reasoned that such a “blanket rule ... mak[ing] the nature, extent, and other terms of co-rights retained by a li-censor irrelevant to the transaction’s HSR reportability is at a minimum overbroad.” PhRMA Comment at 12; JA at 33. The FTC gave two reasons for rejecting the objection. First, the FTC explained that the new approach reflected in the Final Rule treated co-rights consistently with the prior “make, use and sell” approach, “as illustrated by numerous informal interpretations” available on the FTC’s public informal interpretations database. 78 Fed.Reg. at 68,707; JA at 9. Second, the asset transfer determination “does not hinge” on the' scope of the co-right retained, “but on whether the exclusive patent license allows only the licensee to commercially use the patent[.]” Id. ii. Objection to Limitation to Pharmaceutical Industry Second, PhRMA vigorously objected to limiting the Final Rule to the pharmaceutical industry on five separate grounds, ranging from the use by other industries of similar patent rights transfers and extending to challenging the fundamental authority of the agency to issue such a rule. Each of these grounds were addressed in the Final Rule. First, in PhRMA’s view, “there are agreements in other industries that involve the retention of manufacturing rights,” which undermines the agency’s rationale for restricting the Final Rule to the pharmaceutical industry. 78 Fed.Reg. at 68,708; JA at 10. In support of this objection, PhRMA cited examples identified in the Varner Declaration of license agreements in which a party retains manufacturing rights occurring outside of the pharmaceutical industry. See PhRMA Comment at 9 & n.36; JA at 30 & n.36; Varner Decl. at 12-14; JA at 49-51. These agreements include “licensors licensing patent rights] on an exclusive basis ... and retaining] manufacturing rights” in the chemical, electronic component, and medical device industries. Var-ner Decl. at 12-14; JA at 49-51; see, e.g., Varner Decl. at 13; JA at 50 (“Electronic Components: Licensor Sanken Electric Co., Ltd., entered into a Distribution Agreement with Allegro Microsystems, Inc. in which Sanken licensed on an exclusive basis semiconductor technologies and retained the manufacturing rights.”); Var-ner Decl. at 14; JA at 51 (“Medical Device Industry: Licensor Unique Mobility, Inc. entered into a License Agreement and a Supply Agreement with Invacare Corporation in which Unique Mobility licensed patented motor technology for wheelchairs on an exclusive basis and retained the manufacturing rights.”). The FTC declined to expand the rule across industries for two reasons. First, although acknowledging the examples of agreements of purportedly similar rights transfers in other industries, the FTC viewed such arrangements as distinct from the patent rights transfers covered in the Final Rule. Specifically, the FTC explained that the proffered examples “are exclusive distribution agreements, which convey to the licensee only the exclusive right to distribute the patented product ... [and] the licensor retains not just the right to manufacture but all commercially significant rights to the patent,” by contrast to the type of transaction the FTC sought to regulate by promulgation of this rule. 78 Fed.Reg. at 68,708; JA at 10 (citing and distinguishing the Varner Declaration). Second, the FTC noted that, other than these distribution agreements, PhRMA “has not identified any other industry in which exclusive patent licenses, as opposed to exclusive distribution agreements, are common.” 78 Fed. Reg. at 68,709; JA at 11. Second, PhRMA contested the premise expressed in the NPRM restricting the Final Rule to the pharmaceutical industry on the basis that manufacturing is less important in the pharmaceutical industry than the right to commercialize. 78 Fed. Reg. at 68,708; JA at 10. Again, relying on the Varner Declaration, PhRMA’s Comment pointed out that “the right to manufacture in pharmaceuticals can be important,” in part because pharmaceutical products may have patents based on, inter alia, manufacturing technologies. See Varner Decl. at 15; JA at 52. As support, the declaration listed a number of agreements in the pharmaceutical industry that grant manufacturing, process, or production patents. Id. at 15-16; JA at 52-53; see, e.g., Varner Decl. at 16; JA at 53 (“Merck & Co, Inc. entered into an Asset Transfer and License Agreement with Guilford Pharmaceuticals Inc. in which “Process Patents” are specified”); id. (“Amgen Inc. entered into a License and Commercialization Agreement with Inter-Mune Pharmaceuticals, Inc. in which ‘Manufacturing Patents’ are specified”). In response, the FTC stated that the referenced discussion in the NPRM was not “a general assessment of the value of manufacturing,” but only sought to “provide a possible explanation as to why the PNO sees exclusive patent licenses in the pharmaceutical industry structured the way they are structured, namely more and more frequently without the transfer of manufacturing rights.” 78 Fed.Reg. at 68,708; JAatlO. Third, PhRMA objected to the Final Rule’s restriction to the pharmaceutical industry based on the industry’s unique “regulatory hurdles,” “incentives[,] and market structure,” since these characteristics may be found in other industries. Id. The Final Rule acknowledged PhRMA’s identification of other industries that encounter the same “regulatory hurdles” and, further, that have similar “royalty rates” reflecting that “the incentives to maximize future profits are no different.” Id.; see also Varner Decl. at 9-11; JA at 46-48. Nevertheless, the FTC explained that “[t]he.rule is limited to the pharmaceutical industry not because of the uniqueness of the incentives in that industry but because it is the only industry to the PNO’s knowledge in which exclusive patent licenses are prevalent.” 78 Fed. Reg. at 68,708-09; JA at 10-11; see also 78 Fed.Reg. at 68,709; JA at 11 (“[T]he exclusive patent licenses frequently seen in the pharmaceutical industry have not been seen by the PNO in other industries.”). The FTC clarified that its discussion of incentives and market structure was not a justification for restricting the rule, but was raised to “help explain” why transferring patent rights in the pharmaceutical industry “takes the form of an exclusive license instead of an outright sale.” 78 Fed.Reg. at 68,709; JA at 11. Fourth, PhRMA objected on the same grounds raised in this lawsuit, that the FTC does not have the authority to “ex-pandí] the Act’s requirements with respect to only a single industry.” Id. In PhRMA’s view, the plain language and legislative history of the HSR Act reflect Congress’s intent for uniform application of the FTC’s regulations, and, consequently, the FTC has never before promulgated an HSR rule that “increases the [HSR] Act’s requirements for only a single industry, nor has it even tried to do so until now.” PhRMA Comment at 3; JA at 24; see also PhRMA Comment at 4-5; JA at 25-26 (reasoning that Congress “nowhere granted the FTC authority to increase the HSR Act’s reporting burden for only a single industry”). By contrast to other statutory schemes, where Congress has explicitly imposed additional filing requirements on the pharmaceutical industry, Congress has not done so under the HSR Act. PhRMA Comment at 4-5; JA at 25-26. The FTC disagreed with this statutory interpretation for two reasons. First, the FTC stated its view that the Final Rule was not an expansion of the FTC’s statutory authority, nor an expansion of the HSR Act’s coverage, but a rulemaking to determine which types of transactions already covered by the HSR Act constitute asset transfers requiring notification. 78 Fed.Reg. at 68,709; JA at 11. Second, the FTC stated that “Section 18(a)(d)(2)(B), which grants the Commission [exemption] authority ... does not limit the broad and discretionary rulemaking authority granted in Sections 18a(d)(2)(A) and (C).” Id. It further reasoned that “[t]he authority to exempt specific industries or transactions from the Act’s filing requirements is not inconsistent with the authority to implement these requirements on an industry-specific basis prior to consummation of these agreements.” Id. Finally, PhRMA objected that applying the rule selectively on an industry-specific basis was “arbitrary and capricious” for failure to provide sufficient evidentiary support. PhRMA Comment at 8; JA at 29. As support for this objection, PhRMA stated that the FTC does not provide “facts and analysis” or objective evidence in support of the rule but “offers up only its own [agency] ‘expertise,’ ” which is insufficient. Id. Furthermore, since the licensing transactions subject to the rule “are not limited to the pharmaceutical industry” and are found in other industries, which have the same incentives for retaining co-rights and manufacturing rights as the pharmaceutical industry, the industry-specific rule is not well-reasoned. PhRMA Comment at 9-10; JA at 30-31. The FTC disagreed, providing three reasons justifying its adoption of the rule as proposed. First, the FTC explained that the rule applied to the pharmaceutical industry “because the PNO has not received filings over the past five years for exclusive patent licensing arrangements in other industries and requests for guidance on the treatment of exclusive patent licensing arrangements have nearly always come from practitioners in the pharmaceutical industry.” 78 Fed.Reg. at 68,709; JA at 11. The FTC added that its experience allows it “to tailor the rule to the pharmaceutical industry.” Id. Second, the FTC stated that its experience “indicated a need for a rule for the pharmaceutical industry” but that “at this time, the [FTC] has not yet determined that a specific rule is necessary with respect to other industries.” Id. The FTC stated that to the extent they occur, such transfers of exclusive rights may still be reportable “under the Act and existing HSR rules.” Id. Third, the FTC stated that it “may limit rules to those areas where they have observed a problem to be addressed,” id., and that the FTC “need not take an all-or-nothing approach” but may “proceed incrementally,” 78 Fed. Reg. at 68,710; JA at 12. iii. Objections As To Cost As a third category of objections to the Final Rule, PhRMA raised concern over the costs of the proposed rule. Specifically, PhRMA’s objected to the premerger notification requirement because the filing cost would have a negative impact on small businesses, 78 Fed.Reg. at 68,711; JA at 13, by “increas[ing] by at least 50% the number of HSR filings required annually by members of the pharmaceutical industry” resulting in “substantial” costs “with small businesses bearing a significant brunt of’ these costs. PhRMA Comment at 13; JA at 34. The FTC rejected this predicted impact on small businesses for three reasons. First, the FTC stated that a transaction “must be valued at more than $50 million (as adjusted)” to fall under the HSR Act, which “typically [would] not catch most transactions involving small entities.” 78 Fed.Reg. at 68,710; JA at 12. Second, the FTC reasoned that because the HSR Act requires a party to the transaction to have at least $10 million in sales, the “size of person test also ensures that the Act does not regularly reach small entities.” Id. Third, the FTC stated that any small business having to file such notification “would in most instances be filing under the Act as the acquired person in the context of an asset transaction and would therefore be submitting less information” resulting in less of a burden on small entities. Id. Regarding the concerns that such increased filing costs “could chill pharmaceutical transactions,” the FTC responded that such filing costs are relatively small compared to “the profits at stake in the multi-million dollar transactions reportable under the Act,” and thus, would not be a deterrent. Id. Moreover, the FTC pointed out that the parties would likely “conduct a patent valuation as part of their due diligence notwithstanding HSR” and that therefore the 'transferring parties would already be incurring these costs regardless of the promulgation of the Final Rule. Id. Additionally, related to the concern over cost, the FTC analyzed the cost estimates of filing requirements and filing fees submitted by PhRMA in its original comment and supplemental documentation. JA at 72-74 (Letter dated June 7, 2013, from plaintiffs counsel to an FTC Commissioner); 78 Fed.Reg. at 68,711-12; JA at 13-14; see also PhRMA Comment at 13-14; JA at 34-35. The FTC concluded that PhRMA’s estimates were higher than those of the FTC’s, and consequently adjusted its burden increase estimate “out of an abundance of caution and in light of the comments.” 78 Fed.Reg. at 68,712; JA at 14; see also id. (responding to PhRMA comment’s concern regarding the costs of responding to additional information requests). e) PhRMA’s Complaint Less than a week before the effective date of the Final Rule, PhRMA filed the instant action challenging the FTC’s promulgation of the Final Rule. See generally Compl. PhRMA alleges in three claims under the, A PA that the issuance of the Final Rule was: (1) “in excess of [the FTC’s] statutory jurisdiction, authority, or limitations” under the HSR Act, 5 U.S.C. § 706(2)(C); Compl. ¶¶ 89-93 (Count I); (2) “arbitrary, capricious, and an abuse of discretion,” 5 U.S.C. § 706(2)(A); Compl. ¶¶ 94-100 (Count II); and (3) “without observance of procedure required by law,” 5 U.S.C. § 706(2)(D); Compl. ¶¶ 101-06 (Count III). Count Four of PhRMA’s complaint seeks a declaratory judgment “clarifying the legal relations of the parties.” Compl. ¶¶ 107-09 (Count IV). In addition, PhRMA seeks vacatur of the Rule, attorneys’ fees, and a permanent injunction preventing the FTC and its officers from “enforcing, applying, or implementing” the Final Rule. Compl. at 26. The parties’ cross-motions for summary judgment are now pending before this Court. See Pl.’s Mem.; Def.’s Mem. II. STANDARD OF REVIEW A. Summaiy Judgment Standard Pursuant to Federal Rule of Civil Procedure 56, summary judgment may be granted when the Court finds, based upon the pleadings, depositions, and affidavits and other factual materials in the record, “that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a), (c); see Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). “A genuine issue of material fact exists if the evidence, ‘viewed in a light most favorable to the nonmoving party,’ could support a reasonable jury’s verdict for the non-moving party.” Muwekma Ohlone Tribe v. Salazar, 708 F.3d 209, 215 (D.C.Cir.2013) (quoting McCready v. Nicholson, 465 F.3d 1, 7 (D.C.Cir.2006)). When, as here, “a party seeks review of agency action under the APA, the district judge sits as an appellate tribunal. The ‘entire ease’ on review is a question of law.” Am. Bioscience, Inc. v. Thompson, 269 F.3d 1077, 1083 (D.C.Cir.2001) (citing Marshall Cnty. Health Care Auth. v. Shalala, 988 F.2d 1221, 1226 (D.C.Cir.1993); and Univ. Med. Ctr. of S. Nevada v. Shalala, 173 F.3d 438, 440 n. 3 (D.C.Cir.1999)). Accordingly, this Court need not and ought not engage in lengthy fact finding, since “[generally-speaking, district courts reviewing agency action under the APA’s arbitrary and capricious standard do not resolve factual issues, but operate instead as appellate courts resolving legal questions.” James Madison Ltd. by Hecht v. Ludwig, 82 F.3d 1085, 1096 (D.C.Cir.1996); see also Sierra Club v. Mainella, 459 F.Supp.2d 76, 90 (D.D.C.2006) (“Under the APA ... the function of the district court is to determine whether or not as a matter of law the evidence in the administrative record permitted the agency to make the decision it did.”) (quotation marks and citation omitted)); accord McDonough v. Mabus, 907 F.Supp.2d 33, 42 (D.D.C.2012); Wilson v. McHugh, 842 F.Supp.2d 310, 315 (D.D.C.2012). Judicial review is limited to the administrative record. 5 U.S.C. § 706(2) (“[T]he Court shall review the whole record or those parts of it cited by a party....”); Florida Power & Light Co. v. Lorion, 470 U.S. 729, 743-44, 105 S.Ct. 1598, 84 L.Ed.2d 643 (1985) (in applying the arbitrary and capricious standard under the APA, “[t]he focal point for judicial review should be the administrative record already in existence____“ (quoting Camp v. Pitts, 411 U.S. 138, 142, 93 S.Ct. 1241, 36 L.Ed.2d 106 (1973))). B. Chevron Framework The D.C. Circuit has applied the familiar two-step process set out in Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc. (Chevron), 467 U.S. 837, 842, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984), for judicial review determining whether an agency has acted “in excess of statutory jurisdiction, authority or limitations, or short of statutory right” under the A PA. See Am. Fed’n of Gov’t Emps., AFL-CIO, Local 3669 v. Shinseki, 709 F.3d 29, 32-33 (D.C.Cir.2013). The court must begin at Chevron Step One by “ask[ing] whether Congress has directly addressed the precise question at issue.” Mayo Found for Med. Educ. & Research v. United States, 562 U.S. 44, 131 S.Ct. 704, 706, 178 L.Ed.2d 588 (2011) (internal citations omitted). “ ‘If the intent of Congress is clear, that is the end of the matter; for the court, as well as the agency, must give effect to the unambiguously expressed intent of Congress.’ ” City of Arlington, Tex. v. FCC, — U.S.-, 133 S.Ct. 1863, 1868, — L.Ed.2d - (2013) (quoting Chevron, 467 U.S. at 842-43, 104 S.Ct. 2778). A statute that is unambiguous “means that there is ‘no gap for the agency to fill’ and thus ‘no room for agency discretion.’ ” United States v. Home Concrete & Supply, LLC, —— U.S.-, 132 S.Ct. 1836, 1843, 182 L.Ed.2d 746 (2012) (quoting Nat’l Cable & Telecomms. Ass’n v. Brand X Internet Servs., 545 U.S. 967, 982-83, 125 S.Ct. 2688, 162 L.Ed.2d 820 (2005)). To discern whether Congress has addressed the precise question, the court applies the “traditional tools of statutory construction.” Id. at 1844 (quoting Chevron, 467 U.S. at 843 n. 9, 104 S.Ct. 2778). These tools include evaluation of the plain statutory text at issue, the purpose and structure of the statute as a whole, while giving effect, if possible, to every clause and word of a statute, and-where appropriate-the drafting history. See Loving v. IRS, 742 F.3d 1013, 1016 (D.C.Cir.2014) (quoting Pharm. Research & Mfrs. of Am. v. Thompson, 251 F.3d 219, 224 (D.C.Cir.2001)); see also Duncan v. Walker, 533 U.S. 167, 174, 121 S.Ct. 2120, 150 L.Ed.2d 251 (2001); Bell Atl. Tel. Co. v. FCC, 131 F.3d 1044, 1047 (D.C.Cir.1997). If the statute is silent or ambiguous with respect to the specific issue under consideration, however, the analysis shifts to Chevron Step Two, where “the question for the court is whether the agency’s answer is based on a permissible construction of the statute.” City of Arlington, Tex., 133 S.Ct. at 1868. The job of the courts is not to engage in “their own interstitial lawmaking” and “mak[e] public policy by prescribing the meaning of ambiguous statutory commands.” Id. at 1873. Rather, the “archetypal Chevron questions, about how best to construe an ambiguous term in light of competing policy interests” belongs to the “agencies that administer the statutes.” Id. When Congress has delegated to the agency authority to make rules carrying the force of law, and the challenged agency interpretation was promulgated in the exercise of that authority, then the agency’s rule is entitled to deference “as long as it is a permissible construction of the statute, even if it differs from how the court would have interpreted the statute in the absence of an agency regulation.” Sebelius v. Auburn Reg’l Med. Ctr., — U.S. -, 133 S.Ct. 817, 826, 184 L.Ed.2d 627 (2013); see also Nat’l Cable & Telecomms. Ass’n, 545 U.S. at 980, 125 S.Ct. 2688 (“If a statute is ambiguous, and if the implementing agency’s construction is reasonable, Chevron requires a federal court to accept the agency’s construction of the statute, even if the agency’s reading differs from what the court believes is the best statutory interpretation.”). Even when Congress has not provided the agency an express delegation of authority or responsibility “ ‘to implement a particular provision or fill a particular gap, [ ] it can still be apparent from the agency’s generally conferred authority and other statutory circumstances that Congress would expect the agency to be able to speak with the force of law when it addresses ambiguity in the statute or fills a space in the enacted law, even one about which Congress did not actually, have an intent as to a particular result.’ ” Home Concrete & Supply, LLC, 132 S.Ct. at 1843-44 (quoting United States v. Mead Corp., 533 U.S. 218, 229, 121 S.Ct. 2164, 150 L.Ed.2d 292 (2001)). Agencies are owed deference under Chevron even where their interpretation of an ambiguous statutory provision “could be said to delineate the scope of the agency’s jurisdiction.” Verizon v. FCC, 740 F.3d 623, 635 (D.C.Cir.2014) (noting that “the Supreme Court has recently made [this] clear”); see also City of Arlington, Tex., 133 S.Ct. at 1870 (holding that “there is no difference, insofar as the validity of agency action is concerned, between an agency’s exceeding the scope of its authority (its ‘jurisdiction’) and its exceeding authorized application of authority that it unquestionably has” (emphasis in original)). C. Administrative Procedure Act Under the APA, a reviewing court shall “hold unlawful and set aside agency action, findings, and conclusions found to be ... arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law,” 5 U.S.C. § 706(2)(A), “in excess of statutory jurisdiction, authority, or limitations, or short of statutory right,” id. § 706(2)(C), or “without observance of procedure required by law,” id. § 706(2)(D). In evaluating agency actions under the “arbitrary and capricious” standard, courts must consider “whether the [agency’s] decision was based on a consideration of the relevant factors and whether there has been a clear error of judgment.” Marsh v. Oregon Natural Res. Council, 490 U.S. 360, 378, 109 S.Ct. 1851, 104 L.Ed.2d 377 (1989) (citation and internal quotation marks omitted); Citizens to Preserve Overton Park v. Volpe, 401 U.S. 402, 416, 91 S.Ct. 814, 28 L.Ed.2d 136 (1971); Blue Ridge Envtl. Def. League v. Nuclear Regulatory Comm’n, 716 F.3d 183, 195 (D.C.Cir.2013). The scope of review under this standard “is narrow and a court is not to substitute its judgment for that of the agency.” Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co. (State Farm), 463 U.S. 29, 30, 103 S.Ct. 2856, 77 L.Ed.2d 443 (1983); see also Verizon, 740 F.3d at 644 (citing Nat’l Tel. Coop. Ass’n v. FCC, 563 F.3d 536, 541 (D.C.Cir.2009)); Agape Church, Inc. v. FCC, 738 F.3d 397, 408 (D.C.Cir.2013) (citing Cablevision Sys. Corp. v. FCC, 597 F.3d 1306, 1311 (D.C.Cir.2010)). “[T]he arbitrary and capricious standard is ‘highly deferential’ and ‘presumes agency action to be valid[.]’ ” Am. Trucking Ass’ns, Inc. v. Fed. Motor Carrier Safety Admin., 724 F.3d 243, 245 (D.C.Cir.2013) (quoting Am. Wildlands v. Kempthorne, 530 F.3d 991, 997 (D.C.Cir.2008)); Envtl. Def. Fund, Inc. v. Costle, 657 F.2d 275, 283 (D.C.Cir.1981). If an agency, however, “failed to provide a reasoned explanation, or where the record belies the agency’s conclusion, [the court] must undo its action.” Cnty. of Los Angeles v. Shalala, 192 F.3d 1005, 1021 (D.C.Cir.1999). At the very least, the agency must have reviewed relevant data and articulated a satisfactory explanation establishing a “rational connection between the facts found and the choice made.” State Farm, 463 U.S. at 43, 103 S.Ct. 2856 (internal quotation marks omitted); see also Pub. Citizen, Inc. v. FAA, 988 F.2d 186, 197 (D.C.Cir.1993) (“The requirement that agency action not be arbitrary or capricious includes a requirement that the agency adequately explain its result.”). “[A]n agency acts arbitrarily or capriciously if it ‘has relied on factors which Congress has not intended it to consider, entirely failed to consider an important aspect of the problem, offered an explanation for its decision that runs counter to the evidence before the agency, or is so implausible that it could not be ascribed to a difference in view or the product of agency expertise.’” Am. Wildlands, 530 F.3d at 997-98 (quoting State Farm, 463 U.S. at 43, 103 S.Ct. 2856). While the agency’s explanation cannot “run[] counter to the evidence,” State Farm, 463 U.S. at 43, 103 S.Ct. 2856, courts should “uphold a decision of less than ideal clarity if the agency’s path may reasonably be discerned,” Bowman Transp., Inc. v. Arkansas-Best Freight Sys., Inc., 419 U.S. 281, 286, 95 S.Ct. 438, 42 L.Ed.2d 447 (1974). Furthermore, when an agency has acted in an area in which it has “special expertise,” the court must be particularly deferential to the agency’s determinations. Sara Lee Corp. v. Am. Bakers Ass‘n Ret. Plan, 512 F.Supp.2d 32, 37 (D.D.C.2007) (quoting Bldg. & Constr. Trades Dep‘t, AFL-CIO v. Brock, 838 F.2d 1258, 1266 (D.C.Cir.1988)). “Deferring as appropriate to the agency’s expertise and looking only for ‘a rational connection between the facts found and the choice made,’ ” Am. Trucking Ass‘ns, Inc., 724 F.3d at 249 (quoting State Farm, 463 U.S. at 43, 103 S.Ct. 2856), “we remain ever mindful that in performing ‘a searching and careful inquiry into the facts, we do not look at the [agency’s] decision as would a scientist, but as a reviewing court exercising our narrowly defined duty of holding agencies to certain minimal standards of rationality.’ ” Id. (quoting Nat’l Envtl. Dev. Ass’ ns Clean Air Project v. EPA 686 F.3d 803, 810 (D.C.Cir.2012)). III. DISCUSSION In challenging the Final Rule regulating the transfer of certain exclusive patent rights in the- pharmaceutical industry, PhRMA contends that the limited application of the Rule to the pharmaceutical industry exceeds the FTC’s grant of statutory authority under the HSR Act, Compl. ¶¶ 89-93 (Count I), in violation of 5 U.S.C. § 706(2)(C), and was arbitrary and capricious, Compl. ¶¶ 94-100' (Count II), in violation of 5 U.S.C. § 706(2)(A). See PL’s Mem. at 1-2. PhRMA further argues that the Rule should be set aside because the FTC failed to include in the rulemaking record the factual basis for its decision contrary to the procedure required by law, Compl. ¶¶ 101-06 (Count III), in violation of 5 U.S.C. § 706(2)(D), by failing to include in the rulemaking record the factual basis for its decision. See PL’s Mem. at 29-30. The FTC cross-moves for summary judgment, contending: (1) the FTC is entitled to Chevron deference in its interpretation of the HSR Act’s grant of authority to promulgate industry-specific rules, Def.’s Mem. at 9-15; and (2) the FTC provided a reasoned basis for its promulgation of the Rule that was supported by sufficient facts referenced in publicly available information, Def.’s Mem. at 15-28. For the reasons set out below, the Court agrees with the FTC. A. FTC is Entitled to Deference on Scope of Statutory Authority PhRMA contends that the FTC has exceeded its grant of authority under the HSR Act by promulgating a rule that applies only to the pharmaceutical industry because Congress has directly spoken on the issue and expressed its intent to have the premerger notification requirements apply uniformly across all industries. Pl’s Mem. at 16-22. Thus, PhRMA asserts that the Court’s analysis may stop at Chevron Step One because “Congress has directly addressed the precise question at issue.” Mayo Found, for Med. Educ. & Research, 131 S.Ct. at 706 (internal citations omitted). PhRMA supports this argument with four points: (1) the FTC’s power to exempt certain industries from premerger notification requirements under section 18a(d)(2)(B) does not grant the FTC authority to expand selectively the scope of the pre-merger reporting requirements on a piecemeal basis, PL’s Mem. at 16-17; (2) the legislative history of the HSR Act “confirms that Congress did not intend to give the FTC authority to extend the Act’s coverage on such selective terms,” id. at 17-18; (3) industry-specific notification requirements, such as those promulgated in the Final Rule, contravene the purpose of the HSR Act, id. at 18-19; and (4) the FTC’s rulemaking authority, including the discretion to define the terms in the HSR Act under subsection (d)(2)(A), and prescribe other “necessary and appropriate” rules to carry out the purpose of the HSR Act under subsection (d)(2)(C), do not otherwise grant the FTC the authority to issue an industry-specific rule, id. at 19-22. The FTC disputes that Congress has directly addressed the issue in the HSR Act and instead contends, under Chevron Step Two, that the agency’s interpretation of the statute is entitled to deference. See Def.’s Mem. at 11-14. The Court first addresses the parties’ arguments under Chevron Step One and concurs with the FTC that the statute does not expressly address whether the HSR Act premerger notification requirements may be applied selectively to a particular industry. Next, the Court examines the parties’ arguments under Chevron Step Two, finding that the FTC’s interpretation is entitled to deference. 1. HSR Act Does Not Directly Address Industry-Specific Rules Subsection (a) of the HSR Act states that “[e]xeept as exempted pursuant to subsection (c) of this section, no person shall acquire, directly or indirectly, any ... assets of any other person, unless both persons file notification....’’ 15 U.S.C. § 18a(a) (emphasis added). PhRMA seizes upon the “broad, unqualified” “no person” words to conclude that the HSR Act was intended to apply with equal force across all industries, subject only to the exceptions under subsection (c). Pl.’s Mem. at 16; Pl.’s Reply at 4-5. PhRMA’s narrow focus on these two words is too thin a reed to rest its conclusion given the broader language granting the FTC rule-making and exemption authority. To determine the plain meaning of a statute, the court must look not only to “the particular statutory language at issue,” but also to “the language and design of the statute as a whole.” K Mart Corp. v. Cartier, Inc., 486 U.S. 281, 291, 108 S.Ct. 1811, 100 L.Ed.2d 313 (1988) (citations omitted); see also United States v. Ali 718 F.3d 929, 938 (D.C.Cir.2013) (quoting FDA v. Brown & Williamson Tobacco Corp., 529 U.S. 120, 133, 120 S.Ct. 1291, 146 L.Ed.2d 121 (2000), for the proposition that “[i]t is a fundamental canon of statutory construction that the words of a statute must be read in their context and with a view to their place in the overall statutory scheme”). The court assumes “that the legislative purpose is expressed by the ordinary meaning of the words used.” Sec. Indus. Ass’n v. Bd. of Governors, 468 U.S. 137, 149, 104 S.Ct. 2979, 82 L.Ed.2d 107 (1984) (internal quotation and citations omitted). Here, the inclusion of the “no person” words does not manifest Congress’s express intent to have the statute apply uniformly because Congress also enumerated multiple broad exemptions, including a catch-all exemption in subsection (c)(12), which the FTC is authorized to apply. Under subsection (c), certain “classes of transactions” are expressly exempt from the HSR Act, including any “acquisitions of goods or realty transferred in the ordinary course of business,” “acquisitions of bonds, mortgages, deeds of trust, or other obligations which are not voting securities,” “transfers to or from a Federal agency or a State or political subdivision,” and certain “acquisitions, solely for the purpose of investment, by any bank, banking association, trust company, investment company, or insurance company.” 15 U.S.C. § 18a(c)(l), (2), (4), (11). These exemptions militate against finding that Congress intended uniform application of the reporting requirements for three reasons. First, these statutory exemptions distinguish between industries. For example, exemption (c)(ll) exempts the banking industry from certain transactions that other industries must report. This is an explicit recognition by Congress that crafting industry-specific rules may be necessary to achieve the goals of the HSR Act. Second, while some exemptions are circumscribed, Congress also included broad exemptions,' such as transfers “in the ordinary course of business.” id. § 18a(c)(l). Congress granted authority to the FTC to define the transactions constituting transfers “in the ordinary course of business” and thereby limit the otherwise potentially boundless scope of this exemption. See id. § 18a(d)(2)(A) (granting FTC definitional authority). Third, the FTC was granted authority to exempt from the reporting requirement “classes of persons, acquisitions, transfers, or transactions which are not likely to violate the antitrust laws.” See 15 U.S.C. § 18a(d)(2)(B); see also id. § 18a(c)(12) (exempting from reporting requirements “such other acquisitions, transfers, or transactions, as may be exempted under subsection (d)(2)(B) of this section”). While the FTC is not permitted to exempt a specific “person” from the reporting requirements, Section 18a(c)(12) and (d)(2)(B) authorize the FTC to exempt general “classes” of persons or transactions. This plain language is sufficiently broad to cover or exempt entire industries or certain classes of transactions within industries. The broad scope of the exemptions provided in the HSR Act significantly undermines PhRMA’s argument that the “no person” words reflect a Congressional intent for uniform application of the reporting requirements, with only limited exemptions. To the contrary, the nature of the statutory exemptions, combined with the express grants of authority to the FTC to extend those exemptions even more broadly, make plain that the reporting requirements were intended to be a scalpel, rather than a blunt sword, to target precisely those transactions actually posing an antitrust threat. PhRMA acknowledges that subsection (d)(2)(B) grants the FTC exemption authority, but contends that this authority is “narrowly drawn, authorizing the