Slow Download to Devices Remotely

Server Version#: 1.27.0.5897
Player Version#: 9.4.0.33297

Is there any reason that downloads to mobile devices from remote plex servers at direct stream (no transcode) do not reach the maximum upload speed of the server. My server has a max upload of between 35 to 37 mbps but downloads to my phone vary between 6mbps to 25 mbps depending on the media. Is there any reason that it wont reach the maximum speed, my network is not very congested so I know there would be at least 30 mbps always available to upload.

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