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Securus v. FCC, DC, Opp. to Motion for Stay, ICS Rates, 2016

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USCA Case #16-1321

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Filed: 10/13/2016

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UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT

SECURUS TECHNOLOGIES, INC., et al.,
Petitioners,
v.
FEDERAL COMMUNICATIONS
COMMISSION and UNITED STATES
OF AMERICA,
Respondents.

)
)
)
)
) No. 16-1321 and
) consolidated cases
)
)
)
)
)
)

OPPOSITION OF THE RESPONDENTS TO MOTIONS FOR STAY

Renata B. Hesse
Acting Assistant
Attorney General
Robert B. Nicholson
Daniel E. Haar
Attorneys
United States
Department of Justice
Washington, DC 20530

Howard J. Symons
General Counsel
David M. Gossett
Deputy General Counsel
Jacob M. Lewis
Associate General Counsel
Sarah E. Citrin
Counsel
Federal Communications
Commission
Washington, DC 20554
(202) 418-1740

October 13, 2016

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TABLE OF CONTENTS
TABLE OF AUTHORITIES ............................................................................ii 
GLOSSARY..................................................................................................... iv 
BACKGROUND .............................................................................................. 4 
A.  FCC Authority over Inmate Calling and Ancillary Services. ............... 4 
B.  Market Failure in the Inmate Calling Marketplace............................... 4 
C.  2013 Order. ........................................................................................... 5 
D.  2015 Order. ........................................................................................... 7 
E.  Litigation Concerning the 2015 Order. .............................................. 10 
F.  Order under Review............................................................................ 12 
ARGUMENT .................................................................................................. 14 
I. 

The Earlier Stay Orders Do Not Dictate a Stay Here. ............................. 14 

II.  The Petitioners Have Not Satisfied the Stringent Requirements
for a Stay Pending Judicial Review. ........................................................ 17 
A.  The Petitioners Are Not Likely to Succeed on the Merits. ................. 17 
1. 

Inmate calling providers can recover their costs within the
rate caps. ......................................................................................... 17 

2. 

Not all site commissions are legitimate service costs..................... 21 

3. 

The FCC has jurisdiction to cap intrastate rates. ............................ 23 

4. 

The Order is not procedurally defective. ........................................ 25 

B.  The Petitioners Have Not Shown Irreparable Injury. ......................... 26 
C.  A Stay Would Harm Third Parties and the Public Interest. ................ 29 
CONCLUSION ............................................................................................... 30 

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TABLE OF AUTHORITIES
CASES 
Am. Pub. Commc’ns Council v. FCC, 215 F.3d 51
(D.C. Cir. 2000) ...................................................................................................21
Ark. Dairy Co-op Ass’n v. USDA, 573 F.3d 815
(D.C. Cir. 2009) ...................................................................................................26
Chaplaincy of Full Gospel Churches v. England, 454
F.3d 290 (D.C. Cir. 2006) ............................................................................. 26, 27
City of Arlington v. FCC, 133 S. Ct. 1863 (2013) ...................................................24
ConverDyn v. Moniz, 68 F. Supp. 3d 34 (D.D.C. 2014)................................... 27, 29
Ill. Pub. Telecomms. Ass’n v. FCC, 117 F.3d 555
(D.C. Cir. 1997) ............................................................................................ 23, 25
NARUC v. FERC, 475 F.3d 1277 (D.C. Cir. 2007) .................................................22
Nat’l Cable & Telecomms. Ass’n v. Brand X Internet
Servs., 545 U.S. 967 (2005) ...................................................................................3
Nat’l Mining Ass’n v. Jackson, 768 F. Supp. 2d 34
(D.D.C. 2011) .......................................................................................................27
Sw. Bell Tel. Co. v. FCC, 168 F.3d 1344 (D.C. Cir. 1999) .............................. 20–21
Winter v. NRDC, Inc., 555 U.S. 7 (2008) ......................................................... 14, 17
Wisc. Gas Co. v. FERC, 758 F.2d 669 (D.C. Cir. 1985)
(per curiam) ............................................................................................. 27, 28, 29
WMATC v. Holiday Tours, Inc., 559 F.2d 841
(D.C. Cir. 1977) ...................................................................................................17
STATUTES 
47 U.S.C. § 152(b) ...................................................................................................23
47 U.S.C. § 201(b) .......................................................................................... 3, 4, 21
47 U.S.C. § 276 ........................................................................................................28
47 U.S.C. § 276(b)(1).................................................................................................4
47 U.S.C. § 276(b)(1)(A) .............................................................. 3, 4, 17, 20, 21, 23
47 U.S.C. § 276(c) .....................................................................................................4
47 U.S.C. § 276(d) .....................................................................................................4
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RULES 
47 C.F.R. § 64.6000(j) .............................................................................................11
47 C.F.R. § 64.6010 .................................................................................................11
47 C.F.R. § 64.6020(b)(2) ........................................................................................11
47 C.F.R. § 64.6030 ...............................................................................................8, 9
ADMINISTRATIVE MATERIALS 
Implementation of the Pay Telephone Reclassification
and Compensation Provisions of the
Telecommunications Act of 1996, 17 FCC Rcd 21274
(2002) ...................................................................................................................25
Rates for Interstate Inmate Calling Services, 27 FCC Rcd
16629 (2012) ..........................................................................................................6
Rates for Interstate Inmate Calling Services, 28 FCC Rcd
14107 (2013) (2013 Order)..................................................................... 1, 6, 7, 22
Rates for Interstate Inmate Calling Services, 30 FCC Rcd
12763 (2015) (2015 Order)............... 1, 4, 5, 7, 8, 9, 10, 13, 19, 20, 22, 24, 25, 30
Rates for Interstate Inmate Calling Services, DA 161169, 2016 WL 5720877 (Wireline Comp. Bur. Sept.
30, 2016) (Stay Denial) ............................................................... 14, 23, 25–26, 27
Rates for Interstate Inmate Calling Services, FCC 16102, 2016 WL 4212506 (Aug. 9, 2016) (Order) ....................... ……1, 12–13, 15,
18–19, 22–23, 26, 30
Wireline Competition Bureau Addresses Applicable
Rates for Inmate Calling Services, 31 FCC Rcd 2026
(Wireline Comp. Bur. 2016) ................................................................................11
OTHER AUTHORITIES 
D.C. Cir. Rule 18(a)(1) ............................................................................................17
Oxford English Dictionary (2d ed. 1989) ................................................................24

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GLOSSARY
FCC

Federal Communications Commission

GTL

Global Tel*Link

NSA

National Sheriffs’ Association

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Respondents the Federal Communications Commission (FCC) and the United States of America oppose the motions for a stay pending judicial review of the
FCC’s modified rate caps governing calling services for inmates at prisons and
jails.
The FCC first adopted inmate calling rate reforms—on an interim basis, and
governing only interstate calls—in 2013. See Rates for Interstate Inmate Calling
Services, 28 FCC Rcd 14107 (2013) (2013 Order), petitions for review pending in
Securus Techs., Inc. v. FCC, Nos. 13-1280 et al. (D.C. Cir.). In 2015, with the benefit of a more fully developed record, the FCC adopted a new, more comprehensive framework of long-term reforms to govern both interstate and intrastate inmate calls. See Rates for Interstate Inmate Calling Services, 30 FCC Rcd 12763
(2015) (2015 Order), petitions for review pending in Global Tel*Link v. FCC, Nos.
15-1461 et al. (D.C. Cir.) (GTL). In the reconsideration order now under review,
the FCC significantly increased the rate caps adopted in the 2015 Order to take
better account of inmate calling costs that may be incurred by correctional facilities. See Rates for Interstate Inmate Calling Services, FCC 16-102, 2016 WL
4212506 (Aug. 9, 2016) (Order).
In 2014, the Court stayed three rules adopted in the 2013 Order as to which
inmate calling provider Global Tel*Link (GTL) had argued there was inadequate
administrative notice. The Court did not otherwise stay the 2013 Order, allowing

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the FCC’s interim backstop rate caps for interstate calls to take effect. See Order,
Securus at 1 (D.C. Cir. Jan. 13, 2014) (per curiam) (January 2014 Order). In
March 2016, the Court stayed the 2015 Order’s rate caps, which parties had argued
were too low, for both intrastate and interstate calls. See Order, GTL at 1 (D.C. Cir.
Mar. 7, 2016) (per curiam) (March 7 Order). Later, when parties argued that the
FCC had not intended the 2015 Order to expand the scope of the 2013 interim
backstop rate caps—which were readopted in the 2015 Order to remain effective
until the new rate caps could come into force—the Court also stayed the application of those caps to intrastate calls. See Order, GTL at 1 (D.C. Cir. Mar. 23, 2016)
(per curiam) (March 23 Order). But the Court otherwise allowed the 2015 Order
to take effect, including a ban on flat-rate calling as applied to intrastate calls and
limits on charges for services “ancillary” to intrastate calls.
The petitioners contend that the Court’s partial stays of the FCC’s earlier orders warrant an automatic stay of the Order here. But this Order is materially different from those prior orders: By expressly accounting for inmate calling-related
costs incurred by correctional facilities, it significantly increases the applicable interstate and intrastate rate caps in a manner that benefits both inmate calling providers and correctional facilities. The Court’s partial stays of lower rate caps
adopted in prior FCC orders does not alter the petitioners’ burden to justify the extraordinary remedy of a stay with respect to the present Order.
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The petitioners fail to meet their burden to justify a stay. The Communications Act obliges the FCC to ensure that inmate calling providers are “fairly compensated” for inmate calling services. 47 U.S.C. § 276(b)(1)(A); see id. § 201(b).
In the Order under review, the agency found that the inmate calling rate caps, as
now modified, fairly account for the costs incurred by inmate calling providers and
correctional facilities in furnishing inmate calling services. To whatever extent
providers or facilities may lose revenue under the Order, the FCC reasonably determined that ensuring fair compensation for inmate calls does not obligate the
agency to rubber stamp rates at levels above and beyond the legitimate costs of
providing service, including reasonable payments to correctional facilities and a
reasonable rate of return for providers. And the possibility of lost revenue to providers and facilities is far outweighed by the harm to the public interest that would
result from a stay of the Order—in particular to inmates and their families, who
have for far too long been constrained to pay exorbitant inmate calling rates.
Contrary to GTL’s contention (at Mot. 4), the FCC has not engaged in
“gamesmanship” by modifying its rate caps on reconsideration. Indeed, an “agency . . . must consider . . . the wisdom of its policy on a continuing basis.” Nat’l Cable & Telecomms. Ass’n v. Brand X Internet Servs., 545 U.S. 967, 981 (2005) (first
alteration in original; quotation marks omitted). Here, reflecting on the record developed in response to a petition for reconsideration, the FCC found it appropriate
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to increase the rate caps to better account for inmate calling costs that may be incurred by correctional facilities, while ensuring that inmate calling providers are
fairly compensated. That was not gamesmanship but responsible decisionmaking.
The FCC’s rate caps, as modified in the Order, should not be stayed.
BACKGROUND
A. FCC Authority over Inmate Calling and Ancillary Services.
Section 276 of the Communications Act directs the FCC to “promote the
widespread deployment of payphone services to the benefit of the general public.”
47 U.S.C. § 276(b)(1). Payphone services expressly include “the provision of inmate telephone service in correctional institutions, and any ancillary services.” Id.
§ 276(d). Section 276 further directs the FCC to “establish a per call compensation
plan to ensure that all payphone service providers,” including inmate calling providers, are “fairly compensated for each and every completed intrastate and inter1

state call using their payphone[s].” Id. § 276(b)(1)(A). If states have in place “requirements . . . inconsistent with the [FCC]’s regulations, the [agency]’s regulations . . . shall preempt such . . . requirements.” Id. § 276(c).
B. Market Failure in the Inmate Calling Marketplace.
Inmate calling is “a prime example of market failure.” 2015 Order ¶2. Providers do not compete for end users—the inmates and their families who pay for
1

Likewise, the FCC must ensure that “charges . . . for and in connection with” interstate inmate calling services are not “unjust or unreasonable.” Id. § 201(b).
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calls. Rather, providers compete for exclusive contracts to serve a given facility.
Many correctional facilities grant that monopoly franchise based primarily on providers’ offers to make payments known as “site commissions,” which facilities use
“mainly to fund a wide and disparate range of activities . . . unrelated to the costs
of providing [inmate calling].” Id. ¶127. Providers accordingly compete to offer
the highest such payments, which leads to correspondingly higher charges for end
users. Id. ¶¶117–118. Market forces fail to keep those charges in check.
High rates for inmate calling deter communication between inmates and
their families, with substantial and damaging social consequences. Inmates’ families may be forced to choose between putting food on the table or paying hundreds
of dollars each month to keep in touch with their incarcerated loved ones. 2015
Order ¶3. Barriers to communication from high inmate calling rates foster recidivism, with significant costs to taxpayers. Id. ¶¶3–4. And when incarcerated parents
lack regular contact with their children, those children—2.7 million of them nationwide—have higher rates of depression and poor school performance. Id. ¶3 &
n.18. In short, excessive inmate calling rates cause considerable societal harm.
C. 2013 Order.
More than 12 years ago, an individual named Martha Wright, whose grandson was then incarcerated, led a group of inmates and family members (who became known the “Wright Petitioners”) in asking the FCC for relief from exorbitant
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inmate calling rates. The FCC initiated a rulemaking in 2012 to address the Wright
Petitioners’ proposals and the “significant comment” they had generated. Rates for
Interstate Inmate Calling Services, 27 FCC Rcd 16629, 16629 ¶1 (2012).
In response, inmate calling providers gave the agency only limited data concerning their costs. Even so, the record showed a pressing need for agency action
to curb excessive inmate calling charges. In the 2013 Order, the FCC adopted an
interim framework of reforms designed to bring interstate inmate calling rates
more closely in line with provider costs until the agency could craft a longer-term
solution on a more fully developed record. First, the FCC ordered that rates for interstate inmate calls, and fees for ancillary services, be based on costs reasonably
and directly related to the provision of inmate calling. 2013 Order ¶12. The FCC
made clear that site commissions, as a category, do not constitute such costs. Id.
¶55. Second, the FCC established interim “safe-harbor” rate caps beneath which
rates would be presumptively cost-based: $0.12 per minute for “debit and prepaid”
calls (calls paid for through pre-established accounts), and $0.14 per minute for
collect calls (calls not funded through any such account). Id. ¶60. Third, using the
highest cost data in the record to generate a conservative, upper-bound proxy for
cost-based rates, the FCC established uniform interim backstop (or “hard”) caps of
$0.21 per minute for debit and prepaid calls, and $0.25 per minute for collect calls.
See id. ¶¶73–81.
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Several parties petitioned for review of the 2013 Order, and some sought
stays, or partial stays, pending judicial review. GTL sought a stay of the FCC’s
cost-based rule and interim safe-harbor rate caps (plus a related reporting requirement), arguing that the FCC had failed to provide adequate notice that it intended
to adopt those reforms. GTL 2013 Mot. 8–13, 20 (Securus Dkt. #1467732). This
Court granted GTL’s requested relief but otherwise let the 2013 Order take effect.
See January 2014 Order. Rates for interstate inmate calls thus became subject to
the interim backstop rate caps in 2014.
D. 2015 Order.
Meanwhile, the FCC collected further data and public comment on which to
2

base more comprehensive inmate calling reforms. With the benefit of that more
fully developed record, the FCC in the 2015 Order adopted new, comprehensive
reforms for inmate calling and ancillary services, whether interstate or intrastate.
1. Central to the reforms adopted in 2015 was a four-tiered framework of
rate caps for debit and prepaid inmate calls—both interstate and intrastate—which
differentiated among “prisons” ($0.11 per minute) and small, medium, and large
“jails” ($0.22, $0.16, and $0.14 per minute, respectively). 2015 Order ¶9 (table 1).

2

On the FCC’s unopposed motion, this Court placed the challenges to the 2013
Order in abeyance while the agency considered further reforms. Order, Securus at
1 (D.C. Cir. Dec. 16, 2014) (per curiam).
3
For collect calls, a diminishing segment of the inmate calling market, see id. ¶89,
the FCC adopted a “distinct rate structure” on a transitional basis, id. ¶84.
7

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The FCC’s adoption of tiered rate caps reflected its finding in the 2015 Order that
there are economies of scale in serving larger correctional facilities. Id. ¶34. In addition, the 2015 rate caps reflected evidence that jails, in which inmates are housed
for shorter terms, may have a higher rate of turnover (“churn”) than prisons—with
correspondingly higher costs. Id. ¶33; see id. ¶39.
To derive the applicable rate cap for each category of facilities, the FCC
used data from 14 inmate calling providers, “dividing . . . the entirety of all costs
reported by the providers for any category” (with the exception of site commission
payments) “by aggregate minutes of use in that category.” 2015 Order ¶52. In doing so, the FCC took “the [providers’] data at face value,” despite “significant evidence” that providers had “overstated” their costs. Id. ¶53; see id. ¶¶71–75. In addition, despite finding that the imposition of rate caps would result in higher call
volumes that would lower providers’ per-minute costs due to economies of scale,
the FCC did not seek to adjust its per-minute cost calculations to reflect that anticipated consequence of the rate caps. E.g., id. ¶¶34 & n.108, 52 n.170, 70.
As well as adopting tiered rate caps, the FCC prohibited inmate calling providers from charging a flat rate for inmate calls (whether interstate or intrastate).
See 2015 Order ¶105. The FCC also recodified, in amended form, the interim
backstop rate caps first adopted in the 2013 Order. See 47 C.F.R. § 64.6030. In doing so, the FCC provided that the interim caps would “sunset upon the effective8

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ness of the [tiered] rates [adopted in the 2015 Order].” Id.
2. The FCC adhered to its settled view that site commissions, as a category,
are not costs “reasonably related to the provision of [inmate calling services].”
2015 Order ¶123. Accordingly, although the FCC declined to prohibit payments
from inmate calling providers to correctional facilities, it excluded providers’ reported site commission payments from the data used to derive the rate caps. Id.
¶118. Given the benefits to both facilities and inmates from inmate calling services—as well as the prevalence of change-of-law and force majeure clauses in
inmate calling contracts, and the backstop availability of waiver or preemption relief from the FCC—the agency did not believe that correctional authorities would
continue to collect more in site commissions than inmate calling providers could
profitably pay within the new rate caps. See id. ¶¶140, 212–213, 219.
The FCC did recognize in the 2015 Order that some correctional facilities
may incur legitimate costs in providing access to inmate calling services. See 2015
Order ¶139 & n.497. On the available record, the FCC found that such “costs
would likely amount to no more than one or two cents per billable minute.” Id.
¶139. The FCC thus concluded that its tiered rate caps—which, as explained
above, reflected various conservative cost assumptions, see supra p. 8—were “sufficiently generous to cover any [legitimate] costs” to facilities without accounting
for such costs separately. 2015 Order ¶139.
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3. In the 2015 Order, the FCC also addressed the problem of ancillary service charges. To prevent inmate calling providers from exploiting those charges as
a loophole to the new rate caps, the FCC specified a list of permitted fee categories
and limited how much providers may charge for each category based on reasonable
service costs. 2015 Order ¶¶161, 163 (table 4). Those limits applied equally to interstate and intrastate calls. See id. ¶¶193–196.
E. Litigation Concerning the 2015 Order.
Several parties petitioned for review of the 2015 Order and some sought
partial stays pending judicial review. Securus Technologies, Inc. (Securus) and
Telmate, LLC (Telmate) sought a stay of the FCC’s limits on ancillary service
charges, arguing that the agency lacked jurisdiction to regulate such charges, and
that certain of the limits adopted were too low. See Securus 2016 Mot. 4–10 (GTL
Dkt. #1595628); Telmate 2016 Mot. 17–18 (GTL Dkt. #1596259). Telmate, GTL,
and one other inmate calling provider—but not Securus—also sought a stay of the
four-tiered rate caps. See Telmate 2016 Mot. 9–17; GTL 2016 Mot. 9–18 (GTL
Dkt. #1595450); CenturyLink 2016 Mot. 8–16 (GTL Dkt. #1597573). Those providers asserted, among other things, that the rate caps were too low to ensure that
all inmate calling providers could recover their costs in full at all facilities in all jurisdictions. E.g., GTL 2016 Mot. 15–16. In addition, Telmate argued that it was
unreasonable not to account separately in the rate caps for inmate calling-related
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costs that the FCC acknowledged correctional facilities may legitimately incur. See
Telmate 2016 Mot. 12.
In response, the Court stayed the FCC’s four-tiered rate caps (47 C.F.R.
§ 64.6010), as well as a lone portion of the FCC’s rule governing ancillary service
charges that incorporated the tiered rate caps (47 C.F.R. § 64.6020(b)(2)). See
March 7 Order. The Court otherwise allowed the rules adopted in the 2015 Order
to take effect. See id.
Because no party had sought to stay (and thus the Court’s March 7 Order
did not address) the “Inmate Calling Services Interim Rate Cap” rule, which recodified the interim backstop rate caps first adopted in the 2013 Order, see supra pp.
8–9, and because “Inmate Calling Service[s],” under the 2015 Order, include both
interstate and intrastate calls, see 47 C.F.R. § 64.6000(j), the FCC announced that
one effect of the March 7 Order would be to extend the interim backstop rate caps
to intrastate calls until the tiered rate caps could take effect. See Wireline Competition Bureau Addresses Applicable Rates for Inmate Calling Services, 31 FCC Rcd
2026, 2027–28 (Wireline Comp. Bur. 2016). Arguing that the FCC’s view was not
supported by the 2015 Order itself, Securus and Telmate moved the Court to
“modify” or “reconsider” the scope of the March 7 Order. E.g., Securus Modification Mot. 1, 5 (GTL Dkt. #1604434); Telmate Reconsideration Mot. 2, 4 (GTL Dkt.

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4

#1604585). With Judge Millett dissenting, the Court granted those requests. See
March 23 Order.
F. Order under Review.
While the stay litigation concerning the 2015 Order was proceeding, the
FCC received public comment on a petition by an individual named Michael S.
Hamden for partial administrative reconsideration of the 2015 rate caps. Among
other things, Hamden asserted that correctional “facilities do incur some administrative and security costs that would not exist but for [inmate calling services],”
and that the rate caps adopted in the 2015 Order, which excluded all site commission payments reported by inmate calling providers, did not adequately account for
such costs. Order ¶18 (quoting the Hamden Petition). Various commenters agreed
with that view, which also echoed claims in the unfolding litigation over the 2015
Order. See id. ¶¶19–20. The FCC accordingly took a fresh look at the record, focusing on two proposals regarding how to account for facility-incurred costs in the
rate caps. See id. ¶¶4, 22–30. Based on those proposals—one of which was from
the National Sheriffs’ Association (NSA)—the FCC increased its rate caps for debit and prepaid calls by between 18 and over 40 percent: from $0.11 to $0.13 per
minute for prisons, from $0.14 to $0.19 per minute for large jails, from $0.16 to
$0.21 per minute for medium jails, and from $0.22 to $0.31 per minute for small
4

GTL sought equivalent relief but styled its motion as one to “enforce” the earlier
stay. GTL Enforcement Mot. 2 (GTL Dkt. #1604580).
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5

jails. Compare Order ¶3 (table) with 2015 Order ¶9 (table 1). The FCC determined that those increased rate caps would be sufficient to ensure fair compensation to inmate calling providers, as well as to correctional facilities, by fully compensating providers for their costs of service, including reasonable payments to
correctional facilities, while confining rates to levels that are just, reasonable, and
fair for end users. See Order ¶¶4 & 27 n.108.
As explained in the Order, so long as charges to end users remain within the
rate caps, the FCC did not cap site commission payments or restrict the ability of
providers and correctional authorities to negotiate revenue-sharing arrangements.
Order ¶38 n.151; see id. ¶13 nn. 52, 54; id. ¶¶35–38. That approach reflected the
FCC’s determination that rate caps permitting reasonable, but not unlimited, payments to correctional facilities would “address[] the harmful effects of outsized site
commissions” through “market forces, rather than regulatory intervention.” Id. ¶13
n.54 (quotation marks omitted). In reaching that conclusion, the FCC found that
“[c]orrectional authorities have every incentive to accept whatever commissions
providers can pay within the rate caps given the benefits [inmate calling services]
confer[] on both facilities and inmates.” Id.
The petitioners thereupon requested an administrative stay of the Order,
which the FCC’s Wireline Competition Bureau denied on September 30, 2016. See
5

The FCC adopted corresponding increases to the 2015 rate caps for collect calls.
See Order ¶¶12, 22.
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Rates for Interstate Inmate Calling Services, DA 16-1169, 2016 WL 5720877
(Wireline Comp. Bur. Sept. 30, 2016) (Stay Denial).
ARGUMENT
I.

The Earlier Stay Orders Do Not Dictate a Stay Here.
It is well settled that a movant bears the burden to justify the “extraordinary

remedy” of a stay. Winter v. NRDC, Inc., 555 U.S. 7, 22 (2008). Although certain
of these petitioners contend that “respect for this Court’s previous stays” governing
earlier FCC orders lessens the showing required to justify a stay of the Order now
under review, State Mot. 6, there is no reason why that should be so.
The rate caps adopted in the Order are considerably different from those the
FCC adopted in the 2015 Order. The debit and prepaid rate cap for prisons is now
$0.13 per minute rather than $0.11 a minute. For larger jails (with an average daily
population of 1000 inmates or more), it is $0.19 per minute rather than $0.14 per
minute; for medium-sized jails (from 350 to 999 inmates), it is $0.21 per minute
rather than $0.16 per minute; and for smaller jails (with 350 inmates or fewer), it is
$0.31 per minute rather than $0.22 per minute. “[T]he new rate cap for the smallest
jails is over 40 percent higher than the previous cap, the rate caps for medium and
larger jails increased by approximately 30 percent[,] and even the rate caps for
prisons increased by over 18 percent.” Stay Denial ¶15 n.58.
The provider petitioners nonetheless argue that the current rate caps are

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“[e]ssentially the [s]ame” as those previously stayed. Securus Mot. 7; see GTL
Mot. 11; Telmate Mot. 10–14. That argument assumes that the increases adopted in
the Order will go “solely to compensate facilities,” not providers. Telmate Mot. 11;
see GTL Mot. 11; Securus Mot. 7. But as the FCC has made abundantly clear, the
rate increases permitted under the Order allow inmate calling providers to collect
additional revenue from end users, without dictating how much (if any) of that additional revenue must be paid to facilities. See Order ¶¶13 n.52, 38 n.151. The Order “will [thus] ensure that all providers can earn sufficient revenues to cover their
[inmate calling]-related costs while also compensating facilities for reasonable
costs incurred directly as a result of providing [inmate calling services].” Id. ¶4;
see id. ¶¶23, 37 n.147.
Several of the petitioners argue that in staying the intrastate application of
the FCC’s interim rate caps, this Court’s March 23 Order signaled that the agency
lacks jurisdiction to cap intrastate rates. See State Mot. 13; GTL Mot. 6, 17; Telmate Mot. 9. That claim is difficult (if not impossible) to reconcile with the
March 7 Order, which allowed all but one of the FCC’s limits on ancillary service
charges, as well as the agency’s ban on flat-rate calling, to take effect for both interstate and intrastate calls. In any event, the March 23 Order is silent as to the
specific grounds for the Court’s decision. Among other possibilities, the Court may
simply have concluded that the 2015 Order had not made sufficiently clear that the
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interim backstop rate caps would extend to intrastate calls if the tiered rate caps
were stayed.

6

GTL contends that the Court’s prior stay orders have “made clear that the
FCC’s basic approach to [inmate calling services] rate regulation should be reviewed before taking effect.” Mot. 20. That contention is not borne out by the prior
proceedings in this case, nor is it consistent with the standard of review in a stay
proceeding. At every turn, this Court has narrowly tailored the scope of its stay orders, always allowing at least some of the FCC’s reforms to take effect pending judicial review. In 2014, the Court stayed only those rules as to which GTL had argued there lacked adequate administrative notice, declining to stay the interim
backstop rate caps. And when providers argued that the tiered rate caps adopted in
the 2015 Order were too low—among other reasons, because they did not separately account for facility-incurred costs—the Court stayed those rate caps but allowed other rules governing both interstate and intrastate calls to take effect (including, for example, all but one of the FCC’s limits on ancillary service charges).
None of the Court’s prior orders either directly or indirectly constrains the agency’s power to amend its rate reforms pending judicial review.
In short, the petitioners cannot avoid their burden to establish the traditional
6

Contrary to passing suggestions of certain petitioners, see GTL Mot. 17; Telmate
Mot. 6, the March 23 Order cannot plausibly have stayed the interim rate caps as
to intrastate calls on the basis that those caps were too low. No party made that argument to the Court, and the caps remain in effect for interstate calls.
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factors governing the grant of a stay pending judicial review by invoking this
Court’s partial stays of prior FCC orders. The Order under review is distinct from
those prior orders and must be judged on its own merits.
II.

The Petitioners Have Not Satisfied the Stringent Requirements
for a Stay Pending Judicial Review.
Under well-settled standards, the petitioners must make “a clear showing”

that (1) they are likely to prevail on the merits, (2) they will suffer irreparable harm
unless a stay is granted, (3) other interested parties will not be harmed if a stay is
granted, and (4) a stay will serve the public interest. Winter, 555 U.S. at 22; see
WMATC v. Holiday Tours, Inc., 559 F.2d 841, 843 (D.C. Cir. 1977); D.C. Cir.
Rule 18(a)(1). They have not made that showing.
A. The Petitioners Are Not Likely to Succeed on the Merits.
At the outset, the petitioners have not shown a likelihood of success on the
merits. The FCC’s reforms are a reasonable exercise, well supported by an extensive record, of the agency’s statutory authority to ensure that providers of inmate
calling services are paid “fairly”—but not excessively—for their “intrastate and
interstate” calls. 47 U.S.C. § 276(b)(1)(A).
1. Inmate calling providers can recover their costs within the rate caps.
The provider petitioners dispute the FCC’s determination that the new rate
caps are high enough for “all providers [to] earn sufficient revenues to cover their
[inmate calling]-related costs while also compensating facilities for reasonable
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costs incurred directly as a result of providing [inmate calling services].” Order ¶4.
None of the provider petitioners denies the accuracy of that conclusion as it
applies to them individually. Only Securus makes any representation at all concerning its service costs, claiming they “average $0.1776 per minute.” Mot. 7. But
that figure, which does not disclose costs by type of facility or call, is unilluminating. If anything, it suggests Securus’s costs are readily recoverable under the new
rate caps, which for all jails comfortably exceed $0.1776. See supra pp. 12–13.
The crux of the provider petitioners’ claim that the rate caps are too low is
their contention that the increases adopted in the Order will go “solely to compensate facilities.” Telmate Mot. 11. The provider petitioners accordingly contend that
the Court should disregard those increases and instead assess the sufficiency of the
FCC’s new rate caps (at least as to inmate calling providers) as if they remained at
the levels specified in the 2015 Order. See GTL Mot. 12–13; Telmate Mot. 11–12;
Securus Mot. 7–9. But as already explained, see supra p. 15, the additional revenue
available under the Order may flow to facilities, providers, or both.
Telmate challenges the FCC’s conclusion that the new rate caps will allow
all inmate calling providers to recover their costs on the additional basis that the
agency “did not compare providers’ costs inclusive of facilities’ costs with the rate
caps.” Mot. 12. But the FCC increased its rate caps “out of an abundance of caution,” Order ¶14, because it found that “at least some facilities . . . may in some in18

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stances” incur legitimate costs related to inmate calling services that exceed the
“one or two cents a minute” recognized in the 2015 Order, id. ¶17; accord id. ¶13.
Any suggestion that all facilities routinely incur such costs (let alone at levels
commensurate with the increases adopted in the Order) is not supported by the
record. Indeed, both GTL and Securus have represented that most or all of the
functions identified in the record as generating costs for facilities are ordinarily
7

performed by inmate calling providers. See 2015 Order ¶134 & nn.470–472.

Even assuming for argument’s sake that none of the revenue increases allowed under the Order are retained by inmate calling providers, the provider petitioners fail to show that the rate caps are unreasonably low. Importantly, their arguments ignore the increases in call volume—and corresponding increases in revenue and decreases in per-minute costs—that lower rates are bound to produce. See
2015 Order ¶¶6, 34 & n.108, 52 n.170, 56 & n.177, 57 & n.181, 65, 67 & n.203,
70. The provider petitioners themselves have previously acknowledged that the
implementation of the FCC’s 2013 interstate rate caps generated a 15.5 percent increase in interstate call volume. See Joint Br. for the Carriers 39 (GTL Dkt.
7

Securus contends that the rate cap increases adopted in the Order do not reasonably capture facility-incurred costs. Mot. 8. But Securus relies on raw data that the
NSA itself treated only as “inputs that, once compared to and tested by information
elsewhere in the record, could be refined to generate more reliable estimated ranges of facilities’ reasonable costs.” Order ¶28 n.115 (quotation marks omitted). It
was entirely reasonable for the FCC to rely “(in part)” on the NSA’s more refined
cost ranges—“particularly” when a separate proposal from different commenters
“arrive[d] at similar conclusions.” Id.
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#1617174). And that 15.5 percent figure may be conservative. The County of Santa
Clara, for example, reported a more than eight-fold increase in its monthly interstate call minutes after implementing the 2013 rate caps. See Br. for the County of
8

Santa Clara et al. 3 (figure 1) (GTL Dkt. #1638294). As the FCC explained, “because of the general economies of scale in the supply of [inmate calling services],”
any additional costs associated with increased call volumes “will be swamped by
the [associated] revenue increase[s].” 2015 Order ¶34 n.108; accord id. ¶57 n.181.
There is thus no reasonable basis to conclude that the FCC’s rate caps will prevent
inmate calling providers from recovering their legitimate costs of providing service, including a reasonable profit.
Finally, contrary to what GTL and Telmate contend (at GTL Mot. 13; Telmate Mot. 10), the statutory requirement of fair compensation “for each and every . . . call,” 47 U.S.C. § 276(b)(1)(A), does not foreclose the FCC’s use of averaging in setting intrastate rate caps. Nothing in Section 276 suggests that a provider
cannot be “fairly compensated” for each of its calls by reference to the average
costs of providing such calls. And “[t]he use of industry-wide averages in setting
rates is not novel.” Sw. Bell Tel. Co. v. FCC, 168 F.3d 1344, 1352 (D.C. Cir.
8

Even petitioner the State of Oklahoma concedes that its prisons saw a significant
increase in average monthly minutes of inmate calls after the FCC’s interim interstate rate caps took effect (although it seeks to identify other possible causes for
that increase). See State Mot. Ex. C ¶¶13–17. The Wright Petitioners’ consolidated
opposition to these stay motions (lodged on October 13, 2016) sets forth additional
evidence of the demand-stimulation effect of lower inmate calling rates.
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1999). Indeed, this Court has previously upheld the FCC’s use of average call volume to set rates pursuant to Section 276(b)(1)(A). See Am. Pub. Commc’ns Council v. FCC, 215 F.3d 51, 54, 57–58 (D.C. Cir. 2000).
2. Not all site commissions are legitimate service costs.
The provider petitioners also challenge the FCC’s adherence to its decision,
when deriving the rate caps in the 2015 Order, not to take as a given all site commission payments reported by inmate calling providers. See GTL Mot. 9–12; Telmate Mot. 13–14; Securus Mot. 9–13. According to the provider petitioners,
“whatever compensation [a] correctional facility obtains” from an inmate calling
provider is a cost the FCC must build into its rate caps. Securus Mot. 12; see Telmate Mot. 13–14; GTL Mot. 10–11. That is not so.
To begin with, although correctional authorities may choose to award their
monopoly contracts to the provider that offers the largest site commission payments, that cannot by itself transform those payments into a compensable cost. Beyond having been sought (or accepted) by correctional facilities, site commissions
bear no necessary relation to the actual costs of providing inmate calling services.
Requiring the FCC to take all site commission payments as a given would
undermine the agency’s ability to ensure that providers of intrastate inmate calling
services are “fairly,” not excessively, “compensated,” 47 U.S.C. § 276(b)(1)(A),
and that interstate inmate calling charges are “just and reasonable,” id. § 201(b).
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The agency would be compelled to account for whatever payments a correctional
authority might seek, or an inmate calling provider might offer, no matter how far
removed from actual service costs. See 2015 Order ¶142. For example, the FCC
might be required to ensure that inmate calling rates are sufficient to fund the construction of a new highway or hospital. See 2013 Order ¶33 n.125. That result cannot be reconciled with the standard ratemaking practice of disallowing costs not
reasonably incurred. See NARUC v. FERC, 475 F.3d 1277, 1280 (D.C. Cir. 2007).
The provider petitioners contend that the FCC has “ignore[d]” a “market reality” that correctional authorities will demand site commissions in excess of what
providers can profitably pay within the new rate caps. Securus Mot. 12; see GTL
Mot. 10; Telmate Mot. 13. But the FCC reasonably concluded that, given the inherent “benefits” of inmate calling services for “both facilities and inmates,”
“[c]orrectional authorities have every incentive to accept whatever commissions
providers can pay within the rate caps.” Order ¶13 n.54. Thus, as the chief of administrative services for the Oklahoma Department of Corrections (Oklahoma) has
explained, Oklahoma amended its inmate calling contract in the wake of the 2015
Order to reduce inmate calling charges while still providing for site commissions.
See State Mot. Ex. C ¶¶7, 10; see also Securus Mot. 10 (acknowledging that Securus has “been able to reduce or eliminate” some agreements to pay site commissions). There is no reason to believe providers will be forced to pay site commis22

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sions that would preclude the provision of inmate calling services. Particularly given the prevalence of change-of-law and force majeure clauses in inmate calling
contracts, and the backstop availability of waiver or preemption relief from the
FCC, see supra p. 9, the claim that exorbitant site commissions are a necessary
9

cost of providing inmate calling services is fanciful.

3. The FCC has jurisdiction to cap intrastate rates.
GTL, Telmate, and the state petitioners (various states, sheriffs, and the National Association of Regulatory Utility Commissioners) also reprise arguments
that the agency lacks jurisdiction to cap intrastate rates for inmate calls. See State
Mot. 7–13; GTL Mot. 14–16; Telmate Mot. 7–10. That claim flies in the face of
Section 276 of the Communications Act, which directs the FCC “to ensure that all
payphone service providers,” including inmate calling providers, “are fairly compensated for each and every completed intrastate and interstate call using their
payphone.” 47 U.S.C. § 276(b)(1)(A) (emphasis added). As this Court has previously recognized, see Ill. Pub. Telecomms. Ass’n v. FCC, 117 F.3d 555, 561–62
(D.C. Cir. 1997) (IPTA), that clear grant of jurisdiction readily overcomes the ordinary presumption, under Section 2(b) of the Act, 47 U.S.C. § 152(b), that the
agency lacks authority over intrastate communication services.
In the Order under review (at ¶3), the FCC adhered to its conclusion in the
9

GTL’s effort (at Mot. 11) to equate contractually agreed-upon site commissions
with taxes and regulatory fees is likewise unavailing. See Stay Denial ¶17.
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2015 Order that the agency’s jurisdiction to ensure fair compensation for intrastate
inmate calls encompasses the authority to cap rates at levels linked to service costs,
see 2015 Order ¶¶106–116, since otherwise providers could collect excessive (unfair) compensation, see id. ¶¶108, 114. That decision reflects a reasonable interpretation, entitled to deference, of what it means for providers to be “fairly compensated.” See City of Arlington v. FCC, 133 S. Ct. 1863, 1874–75 (2013).
The petitioners contend that the FCC’s authority to ensure fair compensation
is “most naturally read,” GTL Mot. 15, as authorizing the FCC to set “a floor” for
rates but not a “ceiling,” Telmate Mot. 9; see State Mot. 9. To begin with, the question before the Court is whether the FCC’s reading of the statute—not the petitioners’—is reasonable and thus deserves deference. In any event, far from “natural,”
the petitioners’ statutory construction depends on an unjustifiably narrow interpretation of the term “fair,” which the FCC reasonably construed to encompass the
fairness of compensation not just from the standpoint of inmate calling providers,
10

but also from that of consumers. See 2015 Order ¶¶107 n.335, 114 & n.360.

To support their reading of the statute, the petitioners lean heavily on their
view of its “history and purpose.” GTL Mot. 16; see State Mot. 8–9; Telmate
Mot. 8. But the petitioners point to nothing in the legislative history that indicates
10

See also Oxford English Dictionary 671 (2d ed. 1989) (defining “fair,” as in “fair
wages,” to mean “[t]hat [which] may be legitimately aimed at” (emphasis added));
Respondents’ Initial Br. 33 (GTL Dkt. #1635294) (explaining that the terms “fair”
and “just and reasonable” are largely synonymous).
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Congress wished to confine the FCC’s role, under Section 276, to acting when
providers are “undercompensated.” State Mot. 9. Had Congress wished to do so, it
could easily have employed that term, rather than the capacious term “fair.”
The FCC’s interpretation of “fair compensation” is wholly consistent with
agency and judicial precedent. Contrary to what GTL and the state petitioners
claim (at State Mot. 11–12; GTL Mot. 15–16), the FCC has never concluded that it
should deploy Section 276 only to increase payphone rates. Indeed, the FCC has
recognized since at least 2002 that Section 276 requires the agency to consider not
just the interests of payphone providers, but also those of the paying parties. See
2015 Order ¶¶107 n.335, 114 n.360; Implementation of the Pay Telephone Reclassification and Compensation Provisions of the Telecommunications Act of 1996, 17
FCC Rcd 21274, 21302 ¶82 (2002). Consistent with that view, this Court has discussed with approval the possibility of agency action to curb market-based rates
where a payphone service provider has “obtain[ed] an exclusive contract for the
provision of all payphones at an isolated location . . . and is thereby able to charge
an inflated rate for . . . calls made from that location.” IPTA, 117 F.3d at 562.
4. The Order is not procedurally defective.
Finally, Telmate claims that, because the FCC did not grant the precise relief
requested in the Hamden Petition, the Order is “procedurally defective.” Mot. 14;
see id. at 14–15. But the FCC was not reduced to a “binary choice” of either grant25

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ing “the precise relief” Hamden sought or denying reconsideration altogether. Stay
Denial ¶11. Instead, it was free to address the issue raised in the reconsideration
petition in a manner that built on, but did not precisely mirror, the relief requested.
The Hamden Petition reflected concern that the rate caps adopted in the
2015 Order were not high enough “to allow providers to pay facilities for [facilities’] reasonable [inmate calling]-related costs and still earn a profit.” Order ¶11.
Hamden (and the petitioners here) would have preferred the FCC to address that
concern by “mandat[ing] a ‘modest, per-minute facility cost recovery fee that
would be added to the rate caps’” (or else by banning site commissions outright).
Id. (quoting the Hamden Petition). The FCC reasonably chose an alternative solution—higher rate caps allowing for additional revenue that providers may keep or
pay to facilities. That approach was, “at a minimum, a logical outgrowth of the
Hamden Petition.” Id. ¶13 n.54.
B. The Petitioners Have Not Shown Irreparable Injury.
The Court need go no further than determining that the petitioners have
failed to show a likelihood of success on the merits. See Ark. Dairy Co-op Ass’n v.
USDA, 573 F.3d 815, 832 (D.C. Cir. 2009). But the petitioners also fail to satisfy
this Court’s “high standard for irreparable injury.” Chaplaincy of Full Gospel
Churches v. England, 454 F.3d 290, 297 (D.C. Cir. 2006). Under that standard,
“the injury ‘must be both certain and great; it must be actual and not theoretical.’”
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Id. (quoting Wisc. Gas Co. v. FERC, 758 F.2d 669, 674 (D.C. Cir. 1985) (per curiam)). Moreover, “the fact that economic losses may be unrecoverable does not absolve the movant from its considerable burden of proving that those losses are certain, great and actual.” Nat’l Mining Ass’n v. Jackson, 768 F. Supp. 2d 34, 52
(D.D.C. 2011) (quotation marks omitted). A court should look to the claimed loss
only “during the pendency of [the] case,” then ask whether that loss is sufficiently
grave “to threaten the movant’s business.” ConverDyn v. Moniz, 68 F. Supp. 3d 34,
47–48 (D.D.C. 2014).
The petitioners have not met these strict standards. In asserting irreparable
harm, all four rely principally on assertions that they will suffer unrecoverable
11

economic losses. See State Mot. 18; GTL Mot. 18; Telmate Mot. 16–17; Securus
Mot. 14–15. But such losses do not constitute irreparable harm per se, and no petitioner has asserted or shown losses significant enough to justify a stay—
particularly considering the additional revenue made available under the Order (as
compared to under the 2015 Order) to both providers and facilities.
The state petitioners’ only showing of irreparable harm is a prediction that
11

GTL and Securus also contend that renegotiating their existing contracts to comply with the new rate caps would risk their goodwill with customers. GTL Mot.
18–19; Securus Mot. 15–16. It is difficult to see how that could be so; all inmate
calling providers would be subject to the same rate caps, and facilities would presumably blame any need for renegotiation on the FCC. In any event, “providers
willingly entered into their contracts . . . with the knowledge that the [agency] was
undertaking comprehensive [inmate calling] reform and that regulations could
change . . . in ways that might affect those contracts.” Stay Denial ¶27.
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Oklahoma may see its intrastate site commissions reduced from $0.15 per minute
to $0.08 per minute. State Mot. Ex. C ¶¶10–11. That loss of revenue, the state petitioners contend, would “undermine critical correctional and rehabilitative programs.” Mot. 19. But to whatever extent bringing inmate calling rates within the
bounds of what the FCC has determined is “fair” within the meaning of Section
276 of the Communications Act, 47 U.S.C. § 276, may prevent Oklahoma from
continuing to collect outsized site commission payments, site commissions are not
Oklahoma’s only available source of funding for inmate welfare programs. Oklahoma does not assert that the diminution in revenue it projects will threaten the
availability of inmate calling services at its facilities. See State Mot. Ex. C. ¶¶22–
23. That projected diminution in revenue—which in any event may be offset by
increased call volume, see supra pp. 19–20 and note 8—is far from grave or certain enough to show irreparable harm.
As for the provider petitioners, their unspecific and unsupported claims of
potential lost revenue likewise do not show irreparable harm. GTL does not quantify its feared losses at all. See Mot. 18. Securus and Telmate each offer conclusory
affidavits from company executives regarding projected revenue losses that are devoid of analysis or supporting evidence. See Telmate Mot. Attach. A; Securus Mot.
Attach. Boyd. Such “bare allegations” of harm, Wisconsin Gas, 758 F.2d at 674,
which do not appear to account for revenue increases from lower rates, cannot
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support a stay.
Even if the revenue losses that Securus and Telmate claim were better supported, the harms they allege do not come close to threatening their respective
businesses or ability to provide inmate calling services. See ConverDyn, 68 F.
Supp. 3d at 46 (“[M]onetary loss may constitute irreparable harm only where the
loss threatens the very existence of the movant’s business.” (alteration in original;
quoting Wisconsin Gas, 758 F.2d at 674)). Securus projects a loss in annual revenue (at Mot. Attach. Boyd ¶6) that, as a percentage of the company’s total 2015
calling revenue, does not rise to the level of irreparable harm. See id. at 48–49 (citing with approval cases holding that lost revenue amounting to 10 or even 20 per12

cent of a plaintiff’s business is not irreparable harm). And the only harm that
Telmate anticipates is a delay in or reduction of research and compliance efforts.
See Mot. Attach. A ¶¶6, 11.
C. A Stay Would Harm Third Parties and the Public Interest.
Finally, a stay pending appeal would harm third-party consumers of inmate
calling services, as well as the public generally. As the FCC has now repeatedly
recognized, millions of inmates and their families, including some of the most economically disadvantaged members of our society, have paid exorbitant calling rates
12

Securus makes no attempt to show why the “loss in net income” (as distinct from
lost revenue) that it projects (at Mot. Attach. Boyd ¶7) is attributable to the Order,
nor does Securus assert that its projected loss in net income will threaten the survival of its business.
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for far too long. Once in effect, the Order will at last bring those rates in line with
the costs of providing service. Lower rates will make it easier for inmates to stay
connected to their families, reduce recidivism (with attendant savings to taxpayers), and lessen the negative impact on the millions of children with an incarcerated parent. See 2015 Order ¶3.
Moreover, the Order in no way threatens “the availability” or “quality” of
inmate calling services. GTL Mot. 20. Upon a thorough examination of a comprehensive record, the FCC determined that its rate caps will “ensure that all providers
can earn sufficient revenues to cover their [inmate calling]-related costs while also
compensating facilities for reasonable [inmate calling-related] costs incurred directly.” Order ¶4. A number of states and inmate calling providers have made clear
that they agree. E.g., Admin. Stay Opp. of Inmate Calling Solutions, LLC 4 (attached hereto as Attachment A); Br. for Minn. et al. 4–14 (GTL Dkt. #1636355).
And as already noted, see supra p. 28, even Oklahoma makes no contrary showing.
In short, the rate caps adopted in the Order serve the public interest, as well
as the interests of millions of inmates and their families in maintaining affordable
communication with each other. The Order should not be stayed.
CONCLUSION
The Court should deny the motions for stay pending judicial review.

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Respectfully submitted,
Renata B. Hesse
Acting Assistant
Attorney General
Robert B. Nicholson
Daniel E. Haar
Attorneys
United States
Department of Justice
Washington, DC 20530

Howard J. Symons
General Counsel
David M. Gossett
Deputy General Counsel
Jacob M. Lewis
Associate General Counsel
/s/ Sarah E. Citrin
Sarah E. Citrin
Counsel
445 Twelfth Street SW
Washington, DC 20554

October 13, 2016

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Attachment A

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Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of
Rates for Interstate Inmate Calling Services

)
)
) WC Docket No. 12-375
)
)

INMATE CALLING SOLUTIONS, LLC
OPPOSITION TO SECURUS TECHNOLOGIES, INC.’S PETITION FOR STAY
Inmate Calling Solutions, LLC (“ICSolutions”) hereby submits the Petition for Partial
Stay of Order on Reconsideration, filed by Securus Technologies, Inc. (“Petition”).1 The Petition
requests that the FCC stay the effectiveness of parts of the Order on Reconsideration (“Order”)
adopted by the Federal Communication Commission (“FCC” or “Commission”) on August 4,
2016, and released on August 9, 2016, in this Docket,2 which modifies parts of the FCC’s Second
Report and Order, FCC 15-136, released on November 5, 2015 (“2015 Order”)

3

Specifically,

the Petition requests that the FCC delay implementing the rules addressing rates in the Order.4
As provided below, Securus incorrectly claims that (i) it will likely prevail in a future
judicial review; (ii) it will suffer irreparable harm; (iii) other interested parties will not be
substantially harmed if the stay is granted; and (iv) the public interest favors granting a stay. 5

The Petition was filed on August 25, 2016. Pursuant to Section 1.45(d) of the FCC’s rules, this
Opposition is filed within 7 days of submission. See 47 C.F.R. s 1.45(d) (2015).
2
Rates for Interstate Inmate Calling Services, Order on Reconsideration, FCC 16-102, rel. Aug. 9, 2016
(“Order”).
3
Rates for Interstate Inmate Calling Services, Second Report and Order and Third Further Notice of
Proposed Rulemaking, 30 FCC Rcd 12763 (2015) (“2015 Order”), stayed in part by Global Tel*Link, et
al. v. FCC, Order, Case No. 15-1461 (D.C. Cir., Mar. 7, 2016) (staying 47 C.F.R. §§ 64.6010, setting caps
on calling rates and 64.6020(b0(2), setting caps on fees for single-call services).
4
Petition, pg. 1.
5
Petition, pgs. 2-3.
1

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Securus’s arguments fail to satisfy the Virginia Petroleum Jobbers test 6 and, therefore, the
Petition must be dismissed.
For the first prong of the Virginia Petroleum Jobbers test, the Petition is incorrect that an
appeal is likely to be successful.7 Securus basis its contention on three arguments: (A) A stay
will avoid needless expenditure of the FCC’s, Securus’s, and the Court of Appeals’ resources;
(B) The Order sets rates that are below Securus’s cost to provide inmate telephone services
(“ITS”); and (C) The FCC has acted “unreasonably” by avoiding the regulation of ITS providers’
payment of site commissions. These arguments fail to support Securus’s conclusion that a
reversal on appeal is likely to be successful.
Securus’s first argument that its appeal will be successful because a stay will avoid costs
is unsupported. It cannot be reasonably denied that it would be more economically efficient for
all parties and the Court of Appeals to consider the Order in the current Appeal of the 2015
Order (“Appeal”)8 because it changes the 2015 Order. Inarguably, there is no point in arguing
about the aspects of the 2015 Order that have been changed in the Order. While the Court
denied the FCC’s petition for an abeyance of the Appeal,9 it does not mean that the Court will
not address the Order in the Appeal. As Appellants CenturyLink and Global Tel*Link pointed
out in their opposition to an abeyance, the brief can consider the merits of the Order in the
Appeal by allowing supplemental briefs.10 The Court has provided no indication that it intends to
decide the Appeal without considering the changes made by the Order. To the contrary, the
Court Order on the FCC’s Petition for Abeyance orders the parties to “file motions to govern

6

259 F.2d 921 (D.C. Circ., 1958).
Petition, pgs. 3-10.
8
Global Tel*Link, et al. v. FCC, Case No. 15-1461 (D.C. Cir.) (appeal pending) (“Appeal”).
9
Global Tel*Link, et al. v. FCC, Case No. 15-1461, Order (D.C. Cir., Aug. 19, 2016).
10
Global Tel*Link, et al. v. FCC, Case No. 15-1461, Joint Response of Global Tel*Link and CenturyLink
to Respondents’ Motion to Hold Cases in Abeyance, pgs. 2-3 (D.C. Cir., Aug. 1, 2016).
7

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further proceedings within seven days of the deadline to Petition for Review,”11 suggesting that
the Court will at least consider including supplemental briefs in this Appeal. If an appeal of the
Order occurs, it is axiomatic that it would save resources for the Court and all parties to consider
the merits of the Order in the current Appeal as opposed to waiting until the Appeal is finalized.
Thus, Securus’s argument that the Court, the FCC, and any other parties to the Appeal could
avoid “needless expenditure” by staying this Order until after the Appeal is baseless.
Moreover, Securus grasps at straws when it suggests that the Court’s stay of the rates in
the 2015 Order “signal strongly that Securus and petitioners have shown ‘substantial case on the
merits’ for overturning regulations that are premised on ignoring a major component of ICS
costs, namely site commissions.”12 There simply is nothing from the Court’s stay order to
suggest the rationale behind the stay of the rates in the 2015 Order. Indeed, Securus’s purported
reasons contradict the Court’s decision to not stay the interstate rate caps in the FCC’s first
Report and Order and Further Notice of Proposed Rulemaking (“2013 Order”), even though that
order also did not prohibit the payment of site commissions.13
Securus’s arguments that the rates are still below its costs to provide service, even if true,
are insufficient reasons to stay the Order. First, Securus misrepresents the Order when it reports
that the “FCC states and intends that the extra funds generated by the ‘revised rate caps’ will go
to correctional facilities.”14 The FCC made no such statements. The FCC never stated that all
facilities will necessarily incur these costs and, therefore, are entitled to the extra rate caps. Even
11

Global Tel*Link, et al. v. FCC, Case No. 15-1461, Order, pg. 2 (D.C. Cir., Aug. 19, 2016).
Petition, pg. 5.
13
Rates for Interstate Inmate Calling Services, Report and Order and Further Notice of Proposed
Rulemaking, WC Docket No. 12-375, 28 FCC Rcd 14107, ¶ 56 (2013) (“2013 Order”) (“We do not
conclude that ICS providers and correctional facilities cannot have arrangements that include site
commissions.”); see also .Order, pg. 8, footnote 52 (“As explained below at not 151, because we do not
regulate site commissions in this order (and have not done so previously), any revenues derived under
these rate caps may be passed through to facilities.”) (emphasis added).
14
Petition, pg. 6.
12

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Securus’s references to the Order shows that the FCC is merely acknowledging that facilities
may incur costs,15 and the rates were increased to “ensure that all providers can earn sufficient
revenues to cover their ICS-related costs while also compensating facilities for reasonable costs
incurred directly as a result of providing ICS.”16 The FCC has increased rates to allow the
flexibility of providers to compensate facilities for any costs the facilities may incur for
providing ITS, and at the discretion of ITS providers. Despite Securus’s mischaracterization of
the Order, the increase in rates is not a pass-through fee.
Securus has already gone on the record in this Docket to say that its clients incur no costs
to provide ITS, that Securus bears most of the costs related to providing ITS.17 It is reasonable to
presume for the purposes of determining whether to issue a stay that Securus’s clients incur costs
similar to what was proposed by Securus’s counsel, Andrew Lipman, of $0.01 per minute for
facilities with average daily population (ADP) of 1,000 or greater, $0.02 per minute for facilities
with ADP of 300-299, and $0.03 per minute for facilities with ADP below 300.18 The Lipman
proposal was endorsed by Securus, GTL, Telmate, and Pay Tel in a joint filing in this Docket.19
Thus, based on Securus’s own representations, the costs of providing ITS for Securus clients is
low, enabling Securus to keep most, if not all, of the increase in rates.20
Second, Securus’s claim that the new rates are below their costs compares apples to
oranges, as well as contradicting their concessions in this Docket and their current practices.

15

Petition, pg. 6 (citing Order, ¶ 30).
Petition, pg. 6 (citing Order, ¶ 6).
17
Attachment 1, Exhibit 1 (page 4).
18
Attachment 2, page 6.
19
Attachment 3, pgs. 1-2.
20
Illinois Public Telecomm. Ass’n v. FCC, 117 F.3d 555, 570 (D.C. Cir., 1997) (“Under a price cap
system, ‘the regulator sets a maximum price, and the firm selects rates at or below the cap.’ Cost
reductions under the price cap scheme ‘do not trigger reductions in the cap,’ but rather increase the
company’s profits.”).
16

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Securus claims that its average per-minute cost to provide ITS is $0.1776.21 Securus’s alleged
costs are misleading because they lump all their facilities together, while the rate caps in the
Order are differentiated by facility size. Securus’s alleged costs are further contradicted by its
support for the FCC’s rates from the 2015 Order, which are lower than those in the Order, so
long as the FCC prohibited or capped commissions.22 Moreover, Securus’s current practice has
included offers to facilities when rates are capped at the FCC’s rates are inconsistent with their
allegations that they will lose costs if the Order is implemented. In March 2016, at Georgia
DOC, Securus agreed to pay 59.6% commission on calling rates of $0.11 per minute for all
domestic prepaid and debit calling and $0.13 per minute for all domestic collect calling,
including a minimum monthly guarantee (MMG) payment of $325,000.00, and an additional
financial incentive of $4,000,000.00 payment to be made upon contract signing.23 Clearly,
Securus can make a reasonable profit under the FCC’s previous rates when it can afford to
charge the 2015 Order’s rates and still offer a $4,000,000 upfront payment, plus 59.6% in
commissions that are guaranteed to be a minimum of $325,000.00 per month.
Third, Securus’s argument that the FCC must regulate site commissions to rate caps that
result in reasonable and fair profits is false. As a threshold matter, the FCC does not have the
authority to regulate how a provider spends its profits. Indeed, a regulator’s attempt to prohibit
expenditures would raise several constitutional questions, including but not limited to the
freedom of speech in the First Amendment. Nor could the FCC reasonably enforce any such
regulations, particularly considering that the FCC cannot regulate political contributions or

21

Petition, pg. 6.
Attachment 3, pg. 2 (“If, however, the FCC issues an order that (a) adopts the rate caps and fees stated
in the Fact Sheet, and (b) establishes a maximum site commission in the form of a per-minute, capped
additive rate, consistent with the Lipman proposal, the companies will not seek judicial review of these
matters.”)
23
See Attachment 4, pgs 5-6.
22

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charitable contributions – whether they are from the providers themselves or individual
employees, which are protected by the First Amendment. The 2015 Order states: “Accordingly,
if a provider is able to demonstrate that a particular state law or requirement is inconsistent with
the rules we adopt in this Order, we will, consistent with section 276, preempt the inconstant
requirement.”24 Thus, the 2015 Order clearly preempts contracts requiring the provision of ITS
without permitting providers a fair and reasonable profit, as required in Section 276 of the
Telecommunications Act.
Therefore, Securus is disingenuous when it claims to the FCC that it cannot renegotiate
contracts. Nine days before the implementation date, Securus renegotiated all of their contracts
to exclude site commissions as a result of the 2013 Order,25 even though their purported average
costs of $0.177626 are below the maximum rate caps of $0.21 per minute for debit and prepaid
calls and $0.25 per minute for collect calls,27 and despite the fact that the 2013 Order did not
prohibit the payment of site commissions either.28 In addition to agreeing to charge the rates
from the 2015 Order, Securus agreed to charge less than the fee cap from the 2015 Order for live
agent fees, by agreeing to charge $4.75,29 instead of the permissible $5.95 per transaction.30
Nevertheless, even if they could not renegotiate their contracts, they have failed to exhaust their
administrative remedies of seeking the FCC to consider an express preemption, as stated in
Paragraph 211 of the 2015 Order.
24

2015 Order, ¶ 211.
Attachment 5, filed as Wright Petitioners Consolidated Comments, WC Docket No. 12-375 at Exhibit
B (filed mar. 11, 2014).
26
Petition, pg. 6.
27
47 C.F.R. § 64.6030 (implemented in the 2013 Order).
28
2013 Order, ¶56 (“We do not conclude that ICS providers and correctional facilities cannot have
arrangements that include site commissions.”); see also .Order, pg. 8, footnote 52 (“As explained below
at not 151, because we do not regulate site commissions in this order (and have not done so previously),
any revenues derived under these rate caps may be passed through to facilities.”) (emphasis added).
29
Attachment 4, pg. 6.
30
47 C.F.R. § 64.6020(b)(3).
25

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In addition, Securus’s argument that it pays commissions at all of its facilities, and that
should be a reason to stay the rates, ignores the fact that Securus has been making offers that
continue to include the payment of substantial commissions and agreeing to contracts that are
knowingly inconsistent with the 2015 Order. Securus’s conscious and purposeful decision to
make exorbitant commission offers and to continue to charge rates much higher than the rates the
FCC has signaled it has found to be fair, just, and reasonable cannot be a reason to stay the
Order. In many cases, Securus funds their current commission offers by charging much higher
first minute rates for in-state rates that are the equivalent of a per-call charge,31 arguably in
violation of the effective rules of the 2015 Order. And, while Securus is making these claims
that they pay commissions on all of their contracts, they do not provide any specific information.
There are many contracts by ITS providers that have caveats of not paying commissions on
interstate calling revenue or the higher first minute of intrastate revenue. 32 Securus’s argument
that they are bound to pay the commissions while still offering exorbitant commission offers is a
self-perpetuating problem that should not be hold up the FCC’s ability to pass regulations. The
financial offer Securus made to the Georgia DOC in March 2016 is a perfect example. The FCC
could never arrive at a fair, just, and reasonable rate cap if the providers can always claim that
their current contracts are inconsistent with the rates when the providers are purposely entering
into such agreements.

31

See Attachment 6 (showing first minute rates of $5.90 at a jail in Michigan, $5.56 at a jail in Texas,
$4.99 at a jail in Virginia, and $4.00 at a jail in Missouri). These are a sample of jails in a sample of
States, and many more facilities in many more states can have similar higher first-minute rates. Since
these rates were obtained on July 28, 2016, Securus has removed the rate calculator from its public
website to prevent further research.
32
See Wright Petitioners Consolidated Comments, WC Docket No. 12-375 at Ex. B (filed Mar. 11, 2014)
(“Due to the FCC’s Order, Securus no longer will pay site commissions on interstate calls.”) ; see also
Rates for Interstate Inmate Calling Services, Ongoing Payment of Interstate Site commissions in
Contravention of Inmate Rate Order (FCC 13-113), WC Docket No. 12-375 , pg. 2 (posted May 5, 2015)
(showing Securus continued with its policy to not pay site commissions on interstate calls).

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As for the second prong of the Virginia Petroleum Jobbers test, Securus fails to meet the
burden necessary to warrant a stay. Securus’s arguments are essentially that, because the Order
is not in its favor, it will suffer irreparable harm. It is rare that regulations satisfy all interested
participants. Thus, an affected party needs to show more than just that its operations will change
in a somewhat detrimental manner in order to support a stay. Moreover, in this case specifically,
because Securus is charging rates as high as $19.41 for a 15-minute call for some of their
intrastate calls, Securus may very well lose revenue if this Order is not stayed. Indeed, the
Order is intended to stop practices of such high calling rates and those providers who have rode
the wave of high rates will likely suffer. But, it does not necessarily follow that their profits will
be unreasonable or otherwise unfair in the eyes of the law. Regulated providers are entitled to
fair and reasonable profits, not a continuance of their existing revenue.
Securus’s assertion that it spent $3 million to renegotiate 1,500 contracts for the rates in
the 2015 Order is questionable, at best.33 Given the fact that Securus is only installed at a
fraction of the limited number of State DOCs, most of the 1,500 contracts must have been jails.
It is hard to believe that Securus was renegotiating the rates of their existing jail contracts to the
tune of $2,000 a contract prior to the Court of Appeals’ stay of the rates in the 2015 Order on
March 7, 2016, particularly when considering Securus was one of the proponents arguing for the
stay and the implementation dates for jail rates was not until June 20, 2016. Such imprudent
spending cannot be controlled by or otherwise attributable to the FCC.
Similarly, it is unclear why Securus would have such an antiquated and inefficient billing
system that would require 7,200 man hours of re-programming, at an amount of $720,000.00, in
order to change rates.34 In addition to being nonsensical how Securus would have used 7,200
33
34

Petition, pg. 11.
Petition, pg. 12.

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man hours of reprogramming while it was arguing for a stay of the rates, every facility has a
different rate structure. Surely, Securus doesn’t have to reprogram its billing system every time
it gets a contract with a new rate structure. If their billing system can handle multiple rate
structures to accommodate their 1,500 contracts, it is hard to understand why Securus’s
technology department does not have a way to change the rates to the streamlined rates in the
FCC’s 2015 Rate Order. But, even if they did incur those costs for the rates, it is even harder to
believe that they would be unable to utilize at least some of the development for this Order.
Accommodating a new rate structure should not be reinventing the wheel. If it is, again, the FCC
cannot be held accountable for the inefficiencies of a minority of the companies.

It is

management’s decision what technology to use, not the FCC’s decision.
For the third prong of the Virginia Petroleum Jobbers test, Securus ignores the harm that
will occur by continuing with the uncertainty of intrastate rates. Securus presents its stay as
“simply the continuation of the status quo,” but it is anything but status quo in the industry.
After the 2013 Order, many providers increased fees dramatically to maintain their revenue.
Now that fees have been capped, some providers are using significantly higher intrastate rates to
increase revenue. Many States do not regulate intrastate rates at all or in a meaningful manner to
rein in exorbitant rates. The result is industry confusion that has translated to an uncertainty
hindering competition. Providers will be unable to compete unless and until they adopt the
predatory practices of charging substantially higher for intrastate rates and even charging a
higher non-commissionable first minute, to serve as the equivalent of per-call fees without
having to charge an actual per-call fee. Providers that want to operate in the spirit of the law, by
charging fair, just, and reasonable rates, if for no other reason than to avoid future litigation for
unjust and unreasonable rates or other unjust enrichment claims, will be unable to compete and

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will be squeezed out of the market. Moreover, in this day and age of mobile cell phones, and the
disconnection of a phone number’s area code from the actual location of the phone, it does not
make sense why in-state consumers would pay more than six times what their interstate
counterparts pay.35 For those consumers who have non-local, in-state numbers and actually live
outside of the facility’s jurisdiction, and cannot vote for the officials who make the decisions on
commissions in contracts, are the most susceptible to high rates. The regulation of interstate
rates and fees, while leaving intrastate rates unregulated, is causing a great deal of harm.
As for the fourth prong of the Virginia Petroleum Jobbers test, the public interest is not
served by a stay. The failure of the market to effectively control rates is hindering competition.
Whenever one charge is controlled, the industry finds another charge to manipulate, forcing all
providers to choose between charging fair, just, and reasonable rates or charging exorbitant rates.
The market needs certainty in what rates and charges are lawful, while leaving the providers to
the decisions of how to utilize the revenue. That’s what this Order is attempting to accomplish.
Thus, the Petition has (i) failed to establish that an appeal of the Order would be
successful on the merits; (ii) failed to provide any solid evidence that Securus will suffer
irreparable harm; (iii) failed to show the lack of harm to third parties (in fact, great harm be
caused from a delay in the effectiveness of the lower ICS rates); and (iv) failed to show
any public interest benefit from granting a stay. Therefore, Petitioners oppose the Petition for
Partial Stay, and respectfully request that the FCC deny the request as legally unsustainable.
Respectfully submitted this 31st day of August, 2016.
By: /s/Charlena S. Aumiller_________
Charlena S. Aumiller, BPR No. 31465
Attorney for ICSolutions
At Benzie County, Sheriff’s Department in Michigan, a 15-minute call for a prepaid or debit call costs
$3.15 for an interstate call, while an in-state call costs $19.41. See Attachment 6.

35

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CERTIFICATE OF SERVICE
I hereby certify that, on August 31, 2016, the forgoing Opposition was served via
electronic mail on the following persons:
Chairman Tom Wheeler
Federal Communications Commission
Tom.Wheeler@fcc.gov

Commissioner Mignon Clyburn,
Federal Communications Commission
Mignon.Clyburn@fcc.gov

Commissioner Jessica Rosenworcel
Federal Communications Commission
Jessica.Rosenworcel@fcc.gov

Commissioner Ajit Pai
Federal Communications Commission
Ajit.Pai@fcc.gov

Commissioner Michael O’Rielly
Federal Communications Commission
Michael.ORielly@fcc.gov

Howard Symons
General Counsel
Federal Communications Commission
Howard.Symons@fcc.gov

Matthew DelNero, Chief
Wireline Competition Bureau
Federal Communications Commission
Matthew.Delnero@fcc.gov

Lynne Engledow
Deputy Chief
Pricing Policy Division
Wireline Competition Bureau
Federal Communications Commission
Lynne.Engledow@fcc.gov

Stephanie A. Joyce
Arent Fox LLP
1717 K Street N.W.
Washington, D.C. 20036
Stephanie.Joyce@arentfox.com
Counsel for the Petitioner

By: /s/Charlena S. Aumiller_________
Charlena S. Aumiller

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UNITED STATES COURT OF APPEALS FOR THE
DISTRICT OF COLUMBIA CIRCUIT

SECURUS TECHNOLOGIES, INC., ET AL.,
Petitioners,
No. 16-1321 (and
consolidated cases)

V.

FEDERAL COMMUNICATIONS COMMISSION,
AND UNITED STATES OF AMERICA,
Respondents.
CERTIFICATE OF SERVICE
I, Sarah E. Citrin, hereby certify that on October 13, 2016, I
electronically filed the foregoing Opposition of the Respondents to Motions
for Stay with the Clerk of the Court for the United States Court of Appeals
for the District of Columbia Circuit by using the CM/ECF system.
Participants in the case who are registered CM/ECF users will be served by
the CM/ECF system.

/s/ Sarah E. Citrin