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Securus Letter to Fcc Re Transfer of Subsidiaries to Securus Investment Holdings 2013

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14651 Dallas Parkway, 6 th

Dallas, TX 75254-8815

Julie Veach
Chief, Wire1ine Competition Bureau
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554
Re: Domestic 214 Applications Filed for the Indirect Transfer of Control of the
Operating Subsidiaries of Connect Acquisition Corp. to Securus Investment Holdings,
LLC, WC Docket No. 13-79
Dear Ms. Veach:
Applicants Securus Technologies Inc., Connect Acquisition Corp., T -NETIX, Inc., and
T-NETIX Telecommunications Services, Inc. (collectively "Securus") and Securus Investment
Holdings, LLC (collectively "Applicants"), hereby undertake the following commitments and
clarifications of the record in response to concerns raised by Millicorp, d/b/a ConsCallHome, in
the above-referenced Docket. These commitments and clarifications will advance the public
interest by facilitating the objective of the Federal Communications Commission
("Commission") to foster increased communications between inmates and their friends and
families. These commitments and clarifications are in addition to, and not in lieu of,
representations made in the above-referenced applications (''Transfer of Control Application")
and in Applicants' filings in this proceeding. The commitments and clarifications shall be
effective as of the date that control of the operating subsidiaries of Connect Acquisition Corp. is
transferred to Securus Investment Holdings, LLC.
Millicorp has agreed to continue to populate the Line Information Data Base ("LIDB")
for each telephone number that Millicorp assigns to its customers ("Millicorp Numbers") with
sufficient information so that Securus can determine the terminating name and service street
address of the called party. Accordingly, Applicants, and any commonly controlled affiliates of
Applicants, commit to cease and desist any and all blocking of inmate-initiated calls to Millicorp
Numbers except to the extent permitted under the procedures set forth in the Attachment.
Applicants will comply with the procedures set forth in the Attachment and will cooperate and
collaborate in good faith with Millicorp to effectuate the intent of the Attachment. Applicants
believe that these procedures strike a reasonable balance between satisfying the security concerns
expressed by Securus in WC Docket No. 09-144 and ensuring that inmate-initiated call recipients
may benefit from access to Millicorp's services.
The commitments set forth in the Attachment shall not be read or applied to limit or
contravene any obligations imposed on Applicants by virtue of contractual arrangements with
state or local correctional authorities or the inmate calling procedures of such authorities. The
Applicants understand and acknowledge that they may not interpret provisions in such

Julie Veach
April 26, 2013
Page 2
contractual arrangements or inmate calling procedures, including provIsIons regarding the
treatment of call forwarding or call diversion services or schemes, to apply to Millicorp's
services as currently configured. Moreover, Applicants will not in any way solicit or induce,
directly or indirectly, their current or potential future state and local correctional and other
customers to modify or amend their contractual arrangements or inmate calling procedures in
any manner that would prohibit, or allow the blocking of, calls to Millicorp Numbers or suggest
such modifications or amendments.
Applicants agree not to discriminate against Millicorp or its customers with respect to the
completion of inmate-initiated calls to Millicorp Numbers, nor to treat such calls differently from
inmate-initiated calls made to the customers of any other landline or VoIP providers, including,
but not limited to, (i) by requiring Millicorp's customers to comply with any administrative
requirements, such as furnishing phone statements or providing any additional information, not
required of other users of land line or VoIP providers, or (ii) by charging inmates rates to call
Millicorp Numbers that are not consistent with the rates that Applicants charge the customers of
other providers. Applicants will charge inmates local rates to complete calls to Millicorp
Numbers that are local to the confinement facilities from which inmate calls are placed such that
an inmate in a particular facility calling a Millicorp Number with a particular NP A-NXX will be
charged the same rate that SECURUS charges all inmates incarcerated at such facility for
making calls to telephone numbers with the same NPA-NXX.
The Applicants understand that, upon the filing of this letter in the above-referenced
proceeding and the execution of a related agreement, Millicorp shall notify the Commission that
it has no objection to the Commission's grant of the Applicants' Transfer of Control Application
and related international transfer of control application. Applicants have no objection to the
Commission's inclusion of these commitments in any grant of the Transfer of Control
Please contact the undersigned with any questions or concerns regarding this letter.
Thank you.

Dennis 1. Reinho ld
Vice President, General Counsel and Secretary


Tim Meade, President, Millicorp
Phil Marchesiello, Counsel to Millicorp


14651 Dallas Parkway, 6 th
Dallas, TX 75254-8815

LlDB Verification Procedure. Securus will not block an inmate-initiated call to any telephone
number assigned by Millicorp to any of its customers ("Millicorp Number") unless (1) Securus
has first queried a major industry-standard Line Information Data Sase ("LIDS") (i.e., a LIDS that
interconnects daily with the top five largest LlDSs) and determined that either the OCN, name,
or address fields for the Millicorp Number are not populated in such LIDS or are clearly
inaccurate and (2) if these LIDS fields are not populated or are clearly inaccurate, then Securus
has queried a database ("Millicorp-Securus Database") that it intemally maintains that contains
the telephone numbers, names, and addresses of all of Millicorp's customers and determines
that the Millicorp Number is not present in the Millicorp-Securus Database; or (3) the Millicorp
Number is not allowed to be called by the inmate or is required to be blocked pursuant to a
customer contract between Securus and its confinement facility client or the facility's inmate
calling procedures (collectively "Confinement Facility Policies"). (For example, (i) no calls from
inmates incarcerated by the Florida Department of Corrections or the Texas Department of
Criminal Justice may be terminated to prepaid cell phones; (ii) most confinement facilities do not
permit inmate-initiated calls to witnesses, victims, judges, businesses, etc.; (iii) certain facilities
only allow inmate-initiated calls to "allowed lists" of call recipients.) Securus will block an
inmate-initiated call to a Millicorp Number only if Securus is unable to determine the OCN,
name, and address of the customer assigned such Millicorp Number after complying with both
of the foregoing steps (1) and (2), or an applicable Confinement Facility Policy does not allow
the termination of an inmate-initiated call to the Millicorp Number or requires such call to be
blocked as set forth in (3) above.
Millicorp-Securus Database. Securus and Millicorp will establish an operational MillicorpSecurus Database within 30 days. The Millicorp-Securus Database will be automatically
updated by Millicorp (no more often than hourly but no less often than daily) in a mutually
agreeable reasonable manner. During the foregoing 30-day interim period, (1) Securus will
consult Millicorp in a mutually agreeable reasonable manner to confirm the identity and address
of any inmate call recipient whose calls from an inmate or inmates are blocked and who asserts
to Securus that he or she is a Millicorp customer and (2) Securus will provide to Millicorp a
contact person whom Millicorp can consult to resolve any such call blocking issues.
OCNs. To the extent reasonably feasible, Millicorp will populate the OCN field in LIDS for each
Millicorp Number. Millicorp and Securus acknowledge that, to the extent that Millicorp is unable
to populate the OCN field with respect to certain Millicorp Numbers, Securus will be unable to
confirm through LIDS the identity and address of the customer to whom Millicorp assigns such
Millicorp Number. Consequently, the parties will rely on the Millicorp-Securus Database to
enable Securus to confirm the name and address of the Millicorp customer associated with such
Millicorp Number. For purposes of this Attachment, the term "OCN" shall mean the OCN field of
LIDS, as well as a bogus, pseudo, proxy or similar OCN field to which access is made available
by a LIDS administrator to non-ILEC and non-CLEC holders of telephone numbers.
LlDB Verification Testing. Millicorp currently uploads customer information into the LIDS
operated by Transaction Network Services ("TNS"). These uploads occur programmatically
three times per day as new customers are input into Millicorp's customer relationship

Julie Veach
April 26, 2013
Page 4
management system. (TNS processes LlDB data three times each day except Sunday at the
following Pacific times: 4:00am, 10:00am, 6:00pm. On Sunday, batches are only processed at
10:00am and 6:00pm.) The batch files uploaded by Millicorp to the TNS LlDB consist of the
following fields:
OCN (including pseudo, bogus, proxy or similar OCNs)
First name
Last name
Street Address*
Zip Code
* Millicorp shall populate the "Street Address" field in LlDB with its customers' service street
Based on initial testing by Securus, Securus has made a preliminary determination that the
method currently used by Millicorp to insert its customers' information into LlDB is sufficient to
render such information accessible to Securus in a manner that is acceptable to Securus and
that enables Securus to access the information in satisfaction of LlDB Verification Procedure
step (1) above. Millicorp and Securus shall cooperate in good faith for a period of thirty days to
enable Securus to continue and complete such testing. In addition, the parties will collaborate
to accomplish any changes in (A) Millicorp's practices with respect to the population of LlDB
with Millicorp's customer information and (B) Securus' practices with respect to querying such
LlDB databases to obtain Millicorp's customer information as are reasonably necessary to
successfully effectuate LlDB Verification Procedure step (1) above.



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