Before the FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554 IN THE MATTER OF )

) RATES FOR INTERSTATE INMATE CALLING ) WC DOCKET NO. 12-375 SERVICES )

EX PARTE PRESENTATION OF MICHAEL S. HAMDEN1

INTRODUCTION: INTEGRATED SERVICES

Perhaps the greatest threat posed by a lack of regulation, or even inadequate regulation of

the inmate calling services (ICS) industry is its metastasis into a wide range of correctional

programs and services, transforming them into new platforms for the exploitation of prisoners

and their families and centers for unlimited profit. Some large ICS providers2 already utilize

windfall profits generated at the expense of prisoners and their families to purchase and offer

“integrated services”3 to facilities. This presentation examines the issue of “integrated services”

in light of the so-called “Consensus” Proposal of the industry’s largest providers,4 focusing on

the practices of one of those, Securus Technologies, Inc. (“Securus”), based primarily on the

company’s own public statements.

1 An attorney with decades of experience in representing inmates in a variety of matters, including issues pertaining to inmate calling services, Hamden has previously participated in this proceeding, as well as its predecessor, CC Docket No. 96-128. 2 Global Tel*Link Corp. (GTL), Securus Technologies, Inc. (Securus), and Telmate, LLC (Telmate), “represented 85% of the industry revenue in 2013 . . ..” Letter from Brian D. Oliver, CEO, GTL, Richard A. Smith, CEO, Securus, and Kevin O’Neill, CEO, Telmate, to Chairman Tom Wheeler, et al., at 1 (filed 15 September 2014)[hereafter, “Consensus” Proposal]. 3 “Integrated services” refers to such things as electronic management systems for prisoner trust accounts, canteen/commissary operations and sales, email and text services, video visitation, as well as wireless and other emerging technologies. 4 “Consensus” Proposal, supra, n.2.

2

THE “CONSENSUS” PROPOSAL OF THE DOMINANT ICS PROVIDERS

“In the spirit of compromise and consensus,”5 the largest ICS providers (including

Securus) offered a “Consensus” Proposal to reform the industry.6 That proposal does not in fact

represent an industry consensus, and it is a compromise only to the extent that surrender can be

understood as a draw.

The “Consensus” Proposal seeks a uniform rate cap for all ICS calls of $0.20 per minute

for debit and prepaid calls and $0.24 per minute for collect calls, regardless of the type or size of

facility from which they are placed.7 Those proposed rates were not supported by any cost

analysis and, indeed, bear little relation to actual costs reflected in the data incorporated into the

record of this proceeding.

According to prior expert analysis, the cost of providing ICS (exclusive of site

commissions) in larger correctional facilities is $0.04 per minute.8 Since the vast majority of the

population served by GTL, Securus, and Telmate are located in facilities that house at least 1,000

prisoners,9 the proposed “consensus” rates would result in unjustifiable, windfall profits for these

providers.

5 Id., “Consensus” Proposal at p. 2. 6 See, generally, id. (among other things, proposing flat rate caps of between $0.20 to $0.24 per minute, an apparent elimination of payments to correctional authorities in excess of an FCC-determined administrative fee, and the elimination of certain ancillary fees). 7 Id. at p. 2. 8 “Rates for Interstate Inmate Calling Services, Report and Order and Further Notice of Proposed Rulemaking,” 28 FCC Rcd 14107, 78 Fed. Reg. 219 (13 November 2013) at ¶ 26 (analyzing data provided in Expert Report of Stephen E. Siwek on Behalf of Securus (22 April 2013). [Hereafter, Siwek Report]. See also, “Rates for Interstate Inmate Calling Services; Second Further Notice of Proposed Rulemaking; Proposed Rule,” FCC 14–158, at ¶ 60, 79 Fed. Reg. 225 (21 November 2014), pp. 69682 – 69708, at p. 69691 ¶ 60 [hereafter, 2nd FNPRM]. But cf., Reply Comments of Securus Technologies, Inc., on Second Further Notice of Proposed Rulemaking (27 January 2015), at p. 16 (claiming that the Siwek Report provided only “illustrative,” and not “exact” data). 9 See, e.g., Pay Tel Communications, Inc., Notice of Ex Parte Presentation, “Pay Tel Ex Parte Presentation: Further Response to Joint Filing of Global Tel*Link (GTL), Securus, and Telmate,” at 3-4 (7 January 2015)(91% of GTL’s

3

At the same time, the rates proposed by these large providers fail to account for higher

costs in the provision of ICS at smaller correctional facilities. The record is clear that ICS

providers incur significantly higher costs to provide ICS in small jails as compared to very large

jails and prisons, by at least a magnitude of two-to-one.10 One expert opined that, based on data

in the record, the cost of providing collect calling services in facilities with fewer than 350 beds

was at least twice as high as the cost of providing prepaid services in larger facilities.11 This is, in

significant part, attributable to the comparatively shorter terms of incarceration in jails and the

associated high turnover rate, and partly because the economies of scale in serving larger

facilities are not present in smaller ones.12 Indeed, the Wright Petitioners appear to acknowledge

that a higher rate is justified in smaller correctional facilities.13

Thus, the effect of “universal,” flat rates would be to lock in enormous profits for the

dominant ICS providers at the expense of prisoners and their families, while choking off ICS

competitors that serve smaller correctional facilities. And the “Consensus” Proposal’s apparent

limitations on site commission payments to correctional facilities would insulate those profits

and further pad large ICS providers’ bottom line. But that’s just the initial gambit.

customers, 78% of Securus customers, and 53% of Telmate’s customers are housed in prisons or jails with 1,000+ ADP). 10 See, e.g., Wright Petitioners, Comments, at 14, WC Dkt. No. 12-375 (Jan. 12. 2015)(proposing rate caps of $0.08 and $0.10 per minute in small jails with fewer than 350 beds and $0.18 and $0.20 per minute in larger jails and prisons); and see, e.g., id., at Second Further Notice Declaration of Coleman Bazelon, at 12 [hereafter, Bazelon Declaration](analyzing cost differences between jails with less than 350 ADP and jails with greater than 350 ADP and prisons and proposing a $0.10 per minute premium for the smaller facilities). 11 Id., Bazelon Declaration. 12 Id., at p. 7 – 12. Reasons for higher ICS costs in smaller facilities also include more unbillable calls, higher customer service costs, and higher bad debt and refund processing costs. Id. 13 Supra, n.10.

4

METASTASIZING EXPLOITATION THROUGH INTEGRATED ICS While recognizing that the FCC’s jurisdiction may extend to intrastate calling services,

Securus and others argue that such authority does not extend further.14 In other words, they argue

that ICS practices regarding “integrated services” are beyond the reach of federal regulation.

The “Consensus” Proposal encourages the FCC to: [D]efine as impermissible: any payment, service, or product offered to, or solicited by an agency (or its agent) that is not directly related to, or integrated with, the provision of communications services in a correctional facility. This definition permits correctional facilities to obtain new and innovative services that are provided by ICS providers (ranging from email and text services to video visitation, wireless and other emerging technologies), while limiting the ability to incorporate items in the contracting process that bear no relationship to the provision of secure communications in the correctional facility.15 In a footnote to that proposition, the proponents make clear that this definition “would

not broaden the scope of FCC jurisdiction to include such new and innovative services, whether

or not integrated or associated with ICS.”16 But virtually every product and service offered by

ICS providers is arguably “directly related to, or integrated with, the provision of

communications services in a correctional facility.” Thus, the proposed prohibition on site

commissions is illusory. Moreover, even if the FCC should prohibit site commissions on ICS

calls, the proposal would expressly empower ICS providers to continue and even expand the

practice of paying commissions or engaging in profit-sharing for new integrated services. To put

it plainly, the exclusion of “integrated services” from a prohibition on the payment of site

commissions would implicitly authorize continuing, unregulated profiteering on products that are

far removed from inmate calling services. In combination with proposed per-minute rates far in

14 Supra, n.2, “Consensus” Proposal, at p. 2 n. 3. 15 Id., “Consensus” Proposal at p. 4 [footnote omitted]. 16 Id., “Consensus” Proposal at p. 4, n.12.

5

excess of actual costs, industry giants would be positioned to reinvest windfall profits in new

products and technologies, opening a broad horizon of opportunity for unimpeded exploitation.

CASE IN POINT – SECURUS TECHNOLOGIES, INC.

One of the signatories to the “Consensus” Proposal, Securus Technologies, Inc., issued a

press release on 9 April 2014:

Securus Technologies, a leading provider of inmate communications services, investigative technologies, corrections/law enforcement/emergency information technology services, interactive voice response systems, and active global positioning systems (GPS) based offender monitoring devices, announced today that is has invested $175 million in new technologies, products, and patents for the corrections sector over the last two years.17

Just last month, Securus proudly announced its winning bid for the ICS contract with the

San Bernardino County (CA) Sheriff’s Office. In the press release touting the deal, Securus

boasted that the contract will provide the County “a complete upgrade to technology that adds

investigative tools, voice biometric security technology, and free upgrades for the life of the

contract.”18 In the announcement, Robert Pickens, President of Securus, disclosed that: “We

[Securus] have invested +$574 million over the last 3½ years, purchasing and developing new

technologies, some patents, and companies; this is much more than everyone in our sector

combined.”19

17 Press Release, Securus Technologies, Inc., Securus Technologies Announces Investment of $175 Million in New Technologies and Products for Corrections (9 April 2014), available at http://www.prnewswire.com/news-releases/securus-technologies-announces-investment-of-175-million-in-new-technologies-and-products-for-corrections-254567061 html.

18 Press Release, Securus Technologies, Inc., Securus Announces New Customer Agreement with San Bernardino County, California (5 June 2015), available at http://www.prnewswire.com/news-releases/securus-announces-new-customer-agreement-with-san-bernardino-county-california-300094868 html.

19 Id.

6

Indeed, Securus’ own press releases indicate at least sixteen major acquisitions since

March of 2012, fourteen of which have been announced since the release of the Inmate Calling

Services Order in September 2013.20 The table below sets forth details.

ACQUISITION DESCRIPTION OF

PRODUCT/TECHNOLOGY DATE

Primonics, Inc. (purchased) Video Visitation System March 21, 2012 DirectHit Systems, Inc. (Threads™ Product) (purchased)

Sophisticated Investigative and Data Analysis Tools

July 5, 2012

Archonix Systems, LLC (purchased)

Jail Management Systems November 18, 2013

Satellite Tracking of People, LLC (STOP) (purchased)

Active Global Positioning Systems (GPS)

December 20, 2013

Telerus (purchased) Automated Interactive Voice Response System

March 3, 2014

Mobile Marketing Products (Text2Connect™) (purchased)

“Patent Purchase that allows for faster account funding”

April 9, 2014

JLG Technologies, LLC (purchased)

Continuous voice biometric analysis and investigative tools

June 11, 2014

Alternative Monitoring Services (AMS) Division of GSSC (purchased)

Expand capabilities in parolee monitoring

August 4, 2014

Vanu, Inc. (exclusive distribution rights)

Managed Access Systems to limit contraband wireless phones

November 11, 2014

Jobview 2nd Chance (exclusive rights)

Job application assistance to released prisoners

November 21, 2014

CellBlox, Inc. (purchased) Managed Access Systems to limit contraband wireless phones

January 14, 2015

Educational Video Application on ConnectUs (deployed)

Mp4 videos to deliver messages, educational videos, etc.

February 6, 2015

SecureView Tablet (deployed 2,000 Units Quarter 1)

Monthly recurring price to inmate for educational, job applications, etc.

February 6, 2015

Cottonwood Creek Technologies (substantial investment)

“S” Phone - multifunction audio and video inmate phone

March 2, 2015

Securus Video Visitation Installations ($32 m

Corrections-grade multi-purpose touch-screen video visitation units

March 25, 2015

20 Citations to Securus’ press releases detailing such acquisitions are set forth in Exhibit A.

7

investment)JPay, Inc. (purchased) Electronic payments, email,

entertainment and educational appsApril 14, 2015

In a March 2015 announcement regarding Securus’ expansion of its executive team to

manage new acquisitions and the expansion of products and services, CEO Richard A. Smith

opined that these developments were “good for inmates, friends and family, our prison and jail

partners, and our investors.”21 In an April 2014 press release, Mr. Smith disclosed the strategy:

“We have created the broadest product set in the corrections industry over the last two (2) years

and have invested $175 million – now we want to fully integrate these and achieve all of the

value creation that we expected.”22

In May 2015, Securus announced that it was opening an “industry leading technology

center” to present more than 700 of its products.23 CEO Smith explained that the center was

“intended to show case how we keep society safe, keep calling rates as low as possible, and keep

prisons and jails as efficient as possible. . . . We have a large responsibility to inmates,

friends/family members, corrections officials, law enforcement, government administrators,

federal and state regulators, witnesses, victims — and all of society.” As part of that May 2015

press release, Securus set forth the following list of products that it is hawking at its technology

center.

21 Press Release, Securus Technologies, Inc., Securus Expands Executive Team to Manage Expanded Portfolio of Products and Acquisitions (17 March 2015), available at http://www.prnewswire.com/news-releases/securus-expands-executive-team-to-manage-expanded-portfolio-of-products-and-acquisitions-300052084 html .

22 Press Release, Securus Technologies, Inc., Robert E. “Bob” Pickens Promoted to President at Securus Technologies (30 April 2014), available at http://www.prnewswire.com/news-releases/robert-e-bob-pickens-promoted-to-president-at-securus-technologies-257361881 html .

23 Press Release, Securus Technologies, Inc., Securus Announces Opening of Industry Leading Technology Center in Dallas, Texas (14 May 2015), available at http://www.prnewswire.com/news-releases/securus-announces-opening-of-industry-leading-technology-center-in-dallas-texas-300083644.html .

8

Product Should Be Included In Cost of Call?

Audio Calling, Call Storage, Call Analysis Possibly Video Visitation No Email No Data Analytics No Tracking Wireless Phones No Jail Management Systems No Parolee GPS and RF Monitoring No Interactive Voice Response Systems No Managed Access Systems (Wireless Contraband) No Inmate Tablets No Inmate Job Searches No Easy/Real Time Emergency Account Funding No Confidential Inmate Reporting No Inmate Education No Telemedicine Applications No Secure Calling Platform Features Possibly Friend and Family Member Quick Funding Options Possibly Securus Patient Portfolio No Of these services, only three of the eighteen seem to be sufficiently related to the

provision of ICS that costs might justifiably be recovered through a reasonable inmate calling

services rate. Indeed, few of these services have any connection to the cost of providing ICS, but

are rather ancillary services offered through software packages that can be integrated into

electronic systems already intrinsic to the provision of ICS services. But the promise of a single,

integrated electronic system capable of managing the wide array of programs and services

provided by correctional professionals at facilities of all types is immediately apparent. The

prospect that such a system could be acquired at no cost, and indeed, that it might actually

generate revenue through fees charged to end-users (prisoners), and/or their families, should be

alarming to the FCC as it would eviscerate other measures intended to effect long-term reform of

the ICS industry.

9

The excerpt below, taken from Securus’ contract with the jail in DeKalb County,

Georgia, shows this business model in an incipient form.24

Exhibit B shows that Securus offered the County a generous 83% commission in order to

win the ICS contract. It then offered a variety of additional “integrated” services, which the

County could elect in exchange for a reduction in that commission percentage. Such services,

which have little or nothing to do with ICS, would be financed by excessive ICS call revenues.

24 DeKalb County, Georgia – Securus contract (March 28, 2013), at Attachment A (Cost Proposal to RFP No. 12 – 05), at p. 6, attached as Exhibit B.

10

But here’s the problem: if the FCC were to proscribe only site commissions generated

from ICS calls, “integrated services” would remain unregulated. ICS providers and correctional

professionals would be free to enter into profit-sharing agreements that continue to exploit

prisoners and their families through the imposition of new fees for programs and services which

have traditionally been an inherent part of the responsibilities performed by correctional

professionals incident to their duty to care for people in their charge. The net effect would be to

enrich ICS providers and to unfairly shift the cost of incarceration from the public to prisoners

and their families. The public policy implications of such an approach are sobering.

Securus clearly understands the potential of this new growth opportunity, as evidenced by

the fact that the company has more than doubled its $175 million investment in “integrated

services” since 2014, to more than $574 million to date25 — “much more than [all other ICS

providers] combined.”26

ANALYSIS OF THE “CONSENSUS” PROPOSAL

ICS providers have shown remarkable creativity and adaptability in their relentless

pursuit of windfall profits. They stubbornly resisted efforts to rein-in their predatory,

monopolistic pricing schemes for calling services, arguing that competition and the “free

market” would eventually settle pricing policies in a manner favorable to consumers. More than

25 Cf., Press Release, Securus Technologies, Inc., Robert E. “Bob” Pickens Promoted to President at Securus Technologies (30 April 2014), available at http://www.prnewswire.com/news-releases/robert-e-bob-pickens-promoted-to-president-at-securus-technologies-257361881 html, with Press Release, Securus Technologies, Inc.,Securus Announces New Customer Agreement with San Bernardino County, California (5 June 2015), available at http://www.prnewswire.com/news-releases/securus-announces-new-customer-agreement-with-san-bernardino-county-california-300094868.html.

26 Statement of CEO Robert E. “Bob” Pickens, Press Release, Securus Technologies, Inc., Securus Announces New Customer Agreement with San Bernardino County, California (5 June 2015), available at http://www.prnewswire.com/news-releases/securus-announces-new-customer-agreement-with-san-bernardino-county-california-300094868.html.

11

a decade of experience and ever-escalating kick backs belied that argument, although it has not

been abandoned. But their strategy seems to have shifted.

While wielding the cudgel of legal arguments that insist on a narrow view of any

regulation, the industry’s largest providers offer an apparent olive branch in the form of the

“Consensus” Proposal, which suggests that regulation of both interstate and intrastate calling

rates might be acceptable. But, the argument goes, the FCC simply lacks legal authority to

regulate industry practices with particular regard to any “integrated services” ICS providers

might wish to offer.

The “Consensus” Proposal is illusory. Those who offer it do not purport to forego their

right to challenge FCC action. On the contrary, they prosecute legal proceedings to forestall the

modest measures that have already been implemented.27 Nor is the “Consensus” Proposal itself

substantive. It fails to proscribe site commissions or profit-sharing, and it appears to seek rates

far in excess of anything remotely just or reasonable in larger correctional facilities.

If the “Consensus” Proposal were adopted, site commissions would be prohibited for all

products or services “not directly related to, or integrated with, the provision of communications

services in a correctional facility.” But since all of the products and services offered by ICS

providers are at least arguably “directly related to, or integrated with, the provision of

communications services in a correctional facility,” then site commissions would be arguably

permissible in all cases.

And the “Consensus” Proposal seeks a uniform rate cap for all ICS calls which far

exceeds the cost of providing ICS in large correctional facilities, while failing to account for

higher costs in the provision of ICS at smaller correctional facilities. The effect of these proposed

27 See, e.g., Securus Technologies, Inc. v. FCC, Nos. 13-1280, 13-1281, 13-1291, 13-1300, Order (D.C. Cir. Jan. 13, 2014).

12

flat rates would be to lock in enormous profits for the dominant ICS providers at the expense of

prisoners and their families, while choking off ICS competitors that serve smaller correctional

facilities.

But the most significant implication of the “Consensus” Proposal is to leave unregulated

the burgeoning field of “integrated services,” including a vast array of software packages that

can be integrated into electronic systems that are already a central component of ICS services.

As has been seen with the practice of paying site commissions, the opportunity for ICS providers

to partner with correctional professionals and agencies to exploit prisoners and their families can

thus be perpetuated and expanded, even if both interstate and intrastate ICS rates are at last

regulated.

CONCLUSION The FCC has a clear and compelling mandate to regulate the ICS industry “[i]n order to

promote competition among payphone service providers and promote the widespread

deployment of payphone services to the benefit of the general public . . ..”28 Under governing

statutes, “[a]ll charges, practices, classifications, and regulations for and in connection with

[wire and radio] communication service, shall be just and reasonable, and any such charge,

practice, classification, or regulation that is unjust or unreasonable is declared to be unlawful . .

..”29 The FCC has jurisdiction, the legal authority, and an unavoidable obligation to address ICS

industry practices in a comprehensive way.

The FCC must at last enact comprehensive regulations that: (1) rein in site commissions,

including in-kind payments, exchanges, allowances, profit-sharing, and all other arrangements

28 47 U.S.C. § 276(b)(1)(A). 29 47 U.S.C. § 201(b) [emphasis added].

13

designed to return a profit to correctional agencies or institutions of government for ICS services

of all kinds (including “integrated services”); (2) limit the rates charged for interstate and

intrastate calls of all kinds (including debit, prepaid, and collect calls) to levels which do not

exceed the actual, reasonable cost of ICS services in the correctional setting, plus a reasonable

return; (3) prescribe service charges (permitting a modest fee to defray the actual cost of debit

and credit card transactions, as well as those involving a live operator); (4) closely scrutinize

fees charged by third-party payment processing companies, permitting no fee that exceeds actual,

reasonable costs with no profit to ICS vendors; (5) eliminate all other ancillary fees; (6) require

that tariffs be filed for additional charges to recover the actual cost of security features employed

at each facility where such service is in place and the charge is being assessed; and (7) prohibit

per-call/per-connection charges, “convenience” payment fees, and all other mechanisms that

result in charges that exceed the established rate caps.

Respectfully submitted this 8th day of July, 2015. ______________________________ Michael S. Hamden

NC State Bar #12752 1612 Homestead Road Chapel Hill, NC 27516 (919) 605 – 2622 M2007Hamden@cs.com

14

EXHIBIT A

Citations to Securus’ Press Releases Announcing Acquisitions Press Release, Securus Technologies, Inc., Securus Technologies, Inc. Announces Acquisition of Primonics, Inc. (21 March 2012) available at http://www.prnewswire.com/news-releases/securus-technologies-inc-announces-acquisition-of-primonics-inc-143386276.html Press Release, Securus Technologies, Inc., Securus Technologies, Inc. Announces Acquisition of DirectHit Systems, Inc. (THREADS Product) (5 July 2012) available at http://www.prnewswire.com/news-releases/securus-technologies-inc-announces-acquisition-of-directhit-systems-inc-threads-product-161229665.html Press Release, Securus Technologies, Inc., Securus Technologies, Inc. Announces Acquisition of Archonix Systems, LLC (18 November 2013) available at http://www.prnewswire.com/news-releases/securus-technologies-inc-announces-acquisition-of-archonix-systems-llc-232351021.html Press Release, Securus Technologies, Inc., Securus Technologies, Inc. Announces Acquisition of Satellite Tracking of People (STOP), LLC (20 December 2013) available at http://www.prnewswire.com/news-releases/securus-technologies-inc-announces-acquisition-of-satellite-tracking-of-people-stop-llc-236746941.html Press Release, Securus Technologies, Inc., Securus Technologies, Inc. Announces Acquisition of Telerus (3 March 2014) available at http://www.prnewswire.com/news-releases/securus-technologies-inc-announces-acquisition-of-telerus-248195901.html Press Release, Securus Technologies, Inc., Securus Technologies, Inc. Announces Acquisition of JLG Technologies and Affiliated Companies (11 June 2014) available at http://www.prnewswire.com/news-releases/securus-technologies-inc-announces-acquisition-of-jlg-technologies-and-affiliated-companies-262787501.html Press Release, Securus Technologies, Inc., Securus Adds Additional Services to Its Industry Leading GPS Offender Monitoring Business and Expands Base of Customers for STOP (4 August 2014) available at http://www.prnewswire.com/news-releases/securus-adds-additional-services-to-its-industry-leading-gps-offender-monitoring-business-and-expands-base-of-customers-for-stop-269879751.html Press Release, Securus Technologies, Inc., Securus Becomes Key Provider of Technology to Limit Contraband Wireless Units for Prisons and Jails in the United States (11 November 2014) available at http://www.prnewswire.com/news-releases/securus-becomes-key-provider-of-technology-to-limit-contraband-wireless-units-for-prisons-and-jails-in-the-united-states-282320981.html

15

Press Release, Securus Technologies, Inc., Securus Acquires Exclusive Rights and Partners With Jobview to Help Released Inmates Find Jobs (21 November 2014) available at http://www.prnewswire.com/news-releases/securus-acquires-exclusive-rights-and-partners-with-jobview-to-help-released-inmates-find-jobs-283489311.html Press Release, Securus Technologies, Inc., Securus Technologies Purchases CellBlox – Key Provider of Technology that Limits Contraband Wireless Use in Prisons and Jails (14 January 2015), available at http://www.prnewswire.com/news-releases/securus-technologies-purchases-cellblox--key-provider-of-technology-that-limits-contraband-wireless-use-in-prisons-and-jails-300020657.html Press Release, Securus Technologies, Inc. Securus Technologies Launches the Educational Video Application for ConnectUs (6 February 2015) available at http://www.prnewswire.com/news-releases/securus-technologies-launches-the-educational-video-application-for-connectus-300029203.html Press Release, Securus Technologies, Inc., Securus Technologies Announces Tablet Shipments to Top 2,000 Units in First Quarter (6 February 2015), available at http://www.prnewswire.com/news-releases/securus-technologies-announces-tablet-shipments-to-top-2000-units-in-first-quarter-300032291.html Press Release. Securus Technologies, Inc., Securus Invests in High Tech Firm Cottonwood Creek Technologies (2 March 2015), available at http://www.syracuse.com/business/prnewswire/index.ssf/:%20http:/www.prnasia.com/sa/2013/10/11/of%20http:/www.DNAPreciousMetals.com?/ny1/story/?catSetID=&catID=&nrid=294690071&page=69 Press Release, Securus Technologies, Inc., Securus Technologies Announces Improved Safety Through Video Visitation (25 March 2015) available at http://www.prnewswire.com/news-releases/securus-technologies-announces-improved-safety-through-video-visitation-300056087.html Press Release, Securus Technologies, Inc., Securus Technologies, Inc. to Acquire JPay Inc. (14 April 2015) available at http://www.prnewswire.com/news-releases/securus-technologies-inc-to-acquire-jpay-inc-300065531.html