Securus Ex Parte Sub

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by c/o Squire Patton Boggs (US) LLP

Securus Ex Parte Submission

2017-07-24

This document pretains to ITC-T/C-20170511-00095 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2017051100095_1251116

S U I R E AJ Squire Patton Boggs (US) LLP ®@©/ 2550 M Street, NW PATTON BOGGS Washington, DC 20037 O +1 202 457 6000 F +1 202 457 6315 squirepattonboggs.com Paul Besozzi T +1 202 457 5292 Paul.Besozzi@squirepb.com VIA ECFS AND IBFS July 24, 2017 Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Ex Parte Submission — WC Docket No. 17—126; TTC—T/C—20170511— 00094; TTC—T/C—20170511—00095 — Securus Investment Holdings, LLC; Securus Technologies, Inc.; T—NETIX, Inc.; and T—NETIX Telecommunications Services, Inc. Dear Ms. Dortch: Securus Investment Holdings, LLC; Securus Technologies, Inc.; T—NETIX, Inc.; and T— NETTIX Telecommunications Services, Inc. (collectively "STT") and SCRS Acquisition Corporation, acting through counsel, note the attached communication submitted to the Commission today regarding inmate calling services rates and other information regarding STI. There is no reference therein to the pending request for approval of the indirect transfer of control of STTI‘s domestic and international Section 214 authority‘ through a parent—level transaction. ‘ Joint Application ofSecurus Investment Holdings, LLC, Transferor, Securus Technologies, Inc., Licensee T—NETIX, Inc., Licensee T—NETIX Telecommunications Services, Inc., Licensee, and SCRS Acquisition Corporation For Grant ofAuthority Pursuant to Section 214 ofthe Communications Act of 1934, as amended, and Sections 63.04 ofthe Commission‘s Rules to Transfer Indirect Ownership and Control ofLicensees to SCRS Acquisition Corporation, WC Docket 17—126 (filed May 11, 2017), ITC—T/C—20170511—00094, ITC—T/C—20170511—00095 (filed May 11, 2017). 44 Offices in 21 Countries Squire Patton Boggs (US) LLP is part of the international legal practice Squire Patton Boggs, which operates worldwide through a number of separate legal entities. Please visit squirepattonboggs.com for more information. min ocne n77C/a /ANMEDINAC

Squire Patton Boggs (US) LLP July 24, 2017 Page 2 Nonetheless, STI, pursuant to Section 1.1206 of the Commission‘s rules," hereby makes this filing in the above referenced dockets. Respectfully submitted, Paul C. Besozzi Squire Patton Boggs (US) LLP 2550 M Street, NWV Washington, DC 20037 202—457—5292 Counselfor Securus Investment Holdings, LLC; Securus Technologies, Inc.; T— NETIX, Inc.; and T—NETIX Te/lecommunications Services, Inc. ce: Chairman Ajit Pai Commissioner Mignon Clyburn Commissioner Michael O‘Rielly Brendan Carr, General Counsel Kris Monteith, Chief, Wireline Competition Bureau Tom Sullivan, Chief, International Bureau Jay Schwarz, Office of Chairman Pai Kristine Fargotstein, Office of Chairman Pai Jim Bird, Office of General Counsel Madeleine Findley, Wireline Competition Bureau Daniel Kahn, Wireline Competition Bureau Jodie May, Wireline Competition Bureau Sherwin Siy, Wireline Competition Bureau Tracey Wilson, Wireline Competition Bureau David Krech, International Bureau Sumita Mukhoty, International Bureau Lee G. Petro, Counsel for Petitioners William B. Wilhelm, Counsel for Transferee. 2 47 C.F.R. § 1.1206. 214 acac asoriadakarninan

Richard A. Smith Chief Executive Officer and SECU RUS Chairman of the Board Technologies July 21, 2017 Hon. Mignon Clyburn Commissioner, Federal Communications Commission 425 12th Street, S.W. Washington, DC 20554 Dear Commissioner Clyburn: I was surprised to see a press report today of your comments at yesterday‘s Broadband Deployment Advisory Committee meeting, at which you reportedly said that some inmate families have been charged "as much as $25 per minute for local calls." 1 hope that your remarks were reported inaccurately, because | am quite sure that no inmate provider has ever charged a per—minute rate anywhere near that level for any kind of call, let alone local. It has to be an error or an extreme outlier. 1 am well aware of your feelings towards Securus and other companies that provide inmate calling services. It is clear you have strong opinions about this topic, and | respect your right to express your views even when | disagree with them. But, as the late Senator Daniel Patrick Moynihan was fond of saying, "Everyone is entitled to their own opinion, but not to their own facts." The fact is that Securus has never charged any inmate or their family a price of $25 per minute for any call. The fact is that our company‘s average revenue from inmate calling, across all types of calls (interstate, intrastate, and local), is about 18 cents per minute. And approximately $.05 to $.06 of that goes to pay site commissions we are obligated to pay under our contracts with correctional facilities. In jurisdictions where there are no commission payments, our rates are substantially lower. If I include all of the "free calls," my average revenue is $.09 per minute — just $.09 per minute! In the past, | have seen you cite a price of $25 for a 15 minute call (which would be about $1.67 per minute). That, of course, is an order of magnitude less than the $25 per minute price you reportedly spoke of yesterday —— but, even so, it is an order of magnitude greater than Securus‘ actual average price. Here are facts that are NEVER reported, but are relevant to treating what we do with respect: + rate2 per minute; 7%, from $.23 per minute to $.18 + Interstate rates have 72% We filed that with the FCC recently as an ex parte; e Video calling has increased exponentially and we charge only $.24 per minute; 4000 International Parkway | Carroliton, Texas 75007 | SecurusTechnologies.com

Commissioner Mignon Clyburn July 21, 2017 Page 2 of 2 y for all services; t we c average $4C0 y ' s including education, audio calling, video calling, tablets, book downloads, email, religious/bible downloads, law library, facility operating procedures, newspaper downloads, commissary ordering, music downloads, and more. We are actively investing in inmate education, recidivism reduction, and corrections welfare programs: 0 for on the job deaths; P _ that trains and finds positions for inmates post release; ® — with a full—time Director to reduce recidivism and assist inmates post release; e And more ... Spreading inaccurate information about our business and our industry has serious consequences. Both correctional facility staff and our own employees are put at risk of harm from persons who are angered by these false and inflammatory reports. | personally have had to obtain 24/7 security protection because of death threats against myself and my family, which were prompted by press reports that grossly exaggerated the amounts Securus charges for telephone calls. 1 respectfully ask that you refrain from mischaracterizing the prices charged by Securus and other inmate calling providers. If you would like to get a better understanding of our pricing and rate structures, I would be pleased to meet with you and provide a briefing. If, after that meeting, you still believe our prices are too high, at least you will be able to base your opinion on accurate data, as opposed to the wildly inflated numbers reported in the press today. In conclusion, | respectfully invite you, the entire Commission, and your staff to our Technology Center in Carrollton, Texas (near Dallas) for a full 2 to 3 hour presentation of technologies and how we are assisting inmate long—term development today. | would love to host you — you can make it a single day trip if you wish. It will change your life! Sincerely, z> 5s o_ es Ze » BA fifiard A. Smith g Chief Executive Officer and Chairman of the Board Securus Technologies, Inc. Cc: Hon. Ajit Pai Hon. Michael O‘Rielly 4000 International Parkway | Carrollton, Texas 75007 | SecurusTechnologies.com


Document Created: 2017-07-24 16:32:04
Document Modified: 2017-07-24 16:32:04
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