PUBLIC NOTICE
Federal Communications Commission
445 12th St., S.W.
Washington, D.C. 20554

News Media Information 202 / 418-0500
Internet: http://www.fcc.gov
TTY: 1-888-835-5322

DA 18-684
July 2, 2018
APPLICATION FILED FOR THE TRANSFER OF CONTROL
OF INMATE CALLING SOLUTIONS, LLC D/B/A ICSOLUTIONS
TO SECURUS TECHNOLOGIES, INC.
PLEADING CYCLE ESTABLISHED
WC Docket No. 18-193
Comments Due: July 16, 2018
Reply Comments Due: July 23, 2018
By this Public Notice, the Wireline Competition Bureau and the International Bureau
(Bureaus) seek comment from interested parties on a joint application filed by TKC Holdings, Inc.
(TKC), Inmate Calling Solutions, LLC d/b/a ICSolutions (ICS), and Securus Technologies, Inc.
(Securus) (together, Applicants), pursuant to section 214 of the Communications Act of 1934, as
amended, and sections 63.04 and 63.24 of the Commission’s rules, requesting Commission approval
to transfer control of ICS to Securus.1
ICS, a California limited liability company, provides telecommunications services to
confinement and correctional facilities in 39 states.2 ICS is a wholly owned direct subsidiary of
Keefe Group, LLC (Keefe), a Missouri limited liability company.3 Keefe, in turn, is a wholly
owned direct subsidiary of TKC, which is indirectly controlled by an affiliate of H.I.G. Capital,
L.L.C., a U.S.-based private equity entity.4 H.I.G. Capital, L.L.C. is ultimately owned and
controlled by Sami Mnaymneh and Anthony Tamer, both U.S. citizens.5
See 47 U.S.C. § 214; 47 CFR §§ 63.04, 63.24. Joint Application of TKC Holdings, Inc, Inmate Calling
Solutions, LLC d/b/a ICSolutions, and Securus Technologies, Inc. for Grant of Authority Pursuant to Section
214 of the Communications Act, as Amended, and Sections 63.04 and 63.24 of the Commission’s Rules to
Transfer Ownership and Control of Inmate Calling Solutions, LLC d/b/a ICSolutions to Securus Technologies,
Inc., WC Docket No. 18-193, IB File No. ITC-T/C-20180612-00109 (filed June 12, 2018) (Application).
1

2

ICS provides service in Alabama, Arizona, California, Colorado, Florida, Georgia, Idaho, Illinois, Indiana,
Iowa, Kansas, Louisiana, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana,
Nebraska, Nevada, New Hampshire, New Mexico, New York, North Carolina, Ohio, Oklahoma, Oregon,
Pennsylvania, South Carolina, South Dakota, Tennessee, Texas, Utah, Virginia, Washington, West Virginia,
Wisconsin, and Wyoming. Application at 2, 13, and Exh. A.
3

Id. at 2 and Exh. B.

4

Id. at 3.

 Securus, a Delaware corporation, provides telecommunications services as part of the
inmate calling services and public payphone services that it provides to or at confinement facilities
in the District of Columbia and every state except Delaware, Hawaii, Rhode Island, and Vermont.6
Securus’s affiliate, T-NETIX Telecommunications Services, Inc., provides telecommunications
services as part of the inmate calling services and public payphone services that it provides to or at
state Department of Corrections confinement facilities in Florida.7
Securus is an indirect wholly-owned subsidiary of SCRS Acquisition Corporation (SCRS)
and in turn its parent, SCRS Holding Corporation (SCRS Parent), both Delaware corporations.8 The
ultimate majority owner of Securus is Platinum Equity Capital Partners IV, L.P. (PECP IV), a
Delaware limited partnership and private equity investment vehicle sponsored by Platinum Equity,
LLC (PE LLC).9 Tom Gores, a U.S. citizen, is the sole manager of PE LLC, and all membership
interests of PE LLC are held in trust by the Gores Trust dated January 26, 1999, as amended, of
which Tom Gores and Holly Gores, also a U.S. citizen, are the trustees.10 Applicants state that no
other person, directly or indirectly, owns or controls a 10 percent or greater interest in Securus.11
All entities are U.S.-based.12
Pursuant to the terms of the proposed transaction, if approved, Securus will acquire all the
issued and outstanding membership interests of ICS from Keefe.13 As a result, ICS will become a
wholly owned, direct subsidiary of Securus and an indirect wholly owned subsidiary of SCRS and
SCRS Parent.14 PECP IV will be the ultimate majority owner of ICS.15
Applicants assert that a grant of the Application will serve the public interest, convenience,
and necessity. They state that ICS will continue to honor correctional facility customer contracts,
retain its existing management team, and provide additional services to customers as a result of the
proposed transaction.16 They further assert that “there are other competitive providers of inmate

5

Id. at Exh. B.

6

Id. at 13-14.

7

Id.

8

Id. at 2.

9

Id.

10

Id. at 8-12 and Exh. B.

11

Id. at 12.

12

Id. at 8-12.

13

Id. at 3.

14

Id.

15

Id.

16

Id. at 3-5.

2

 calling services authorized to operate in various states aside from Securus and ICSolutions”17 and
that approval of the Application will “not foreclose the opportunity for continued competitive
bidding to provide inmate calling services to facilities in the various states in which the two
companies currently operate.”18
GENERAL INFORMATION
The Application referenced herein has been found, upon initial review, to be acceptable for
filing. The Commission reserves the right to return any application if, upon further examination, it
is determined to be defective and not in conformance with the Commission’s rules and policies.
Interested parties may file comments and petitions on or before July 16, 2018, and reply
comments or oppositions to petitions on or before July 23, 2018. Comments may be filed using the
Commission’s Electronic Comment Filing System (ECFS) or by paper. All filings must be
addressed to the Commission’s Secretary, Office of the Secretary, Federal Communications
Commission.


Electronic Filers: Comments may be filed electronically by accessing ECFS
at http://apps.fcc.gov/ecfs/.



Paper Filers: Parties who choose to file by paper must file an original and one copy of each
filing. Paper filings can be sent by hand or messenger delivery, by commercial overnight
courier, or by first-class or overnight U.S. Postal Service mail.


All hand-delivered or messenger-delivered paper filings for the Commission’s
Secretary must be delivered to FCC Headquarters at 445 12th St., SW, Room TWA325, Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All
hand deliveries must be held together with rubber bands or fasteners. All envelopes
and boxes must be disposed of before entering the building.



Commercial overnight mail (other than U.S. Postal Service Express Mail and
Priority Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD
20743.



U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445
12th Street, SW, Washington DC 20554.

People with Disabilities: To request materials in accessible formats for people with
disabilities (braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or
call the Consumer and Governmental Affairs Bureau at 202-418-0530 (voice), 1-888-835-5322 (tty).
In addition, please provide one copy of each pleading to each of the following:
1) Jodie May, Wireline Competition Bureau, jodie.may@fcc.gov;
2) Sumita Mukhoty, International Bureau, sumita.mukhoty@fcc.gov;
3) Jim Bird, Office of General Counsel, transactionteam@fcc.gov;
17

Id. at 5.

18

Id.

3

 The proceeding in this Notice shall be treated as a permit-but-disclose proceeding in
accordance with the Commission’s ex parte rules.19 Persons making ex parte presentations must file
a copy of any written presentation or a memorandum summarizing any oral presentation within two
business days after the presentation (unless a different deadline applicable to the Sunshine period
applies). Persons making oral ex parte presentations are reminded that memoranda summarizing the
presentation must (1) list all persons attending or otherwise participating in the meeting at which the
ex parte presentation was made, and (2) summarize all data presented and arguments made during
the presentation. If the presentation consisted in whole or in part of data or arguments already
reflected in the presenter’s written comments, memoranda, or other filings in the proceeding, then
the presenter may provide citations to such data or arguments in his or her prior comments,
memoranda, or other filings (specifying the relevant page and/or paragraph numbers where such
data or arguments can be found) in lieu of summarizing them in the memorandum. Documents
shown or given to Commission staff during ex parte meetings are deemed to be written ex parte
presentations and must be filed consistent with rule 1.1206(b), 47 CFR § 1.1206(b). Participants in
this proceeding should familiarize themselves with the Commission’s ex parte rules.
To allow the Commission to consider fully all substantive issues regarding the Application in
as timely and efficient a manner as possible, petitioners and commenters should raise all issues in
their initial filings. New issues may not be raised in responses or replies.20 A party or interested
person seeking to raise a new issue after the pleading cycle has closed must show good cause why it
was not possible for it to have raised the issue previously. Submissions after the pleading cycle has
closed that seek to raise new issues based on new facts or newly discovered facts should be filed
within 15 days after such facts are discovered. Absent such a showing of good cause, any issues not
timely raised may be disregarded by the Commission.
For further information, please contact Jodie May, Wireline Competition Bureau, (202) 4180913; or Sumita Mukhoty, International Bureau, (202) 418-7165.
.
- FCC –

19

47 CFR § 1.1200 et seq.

20

See 47 CFR § 1.45(c).

4

 SECTION 214 AUTHORIZATIONS
A.

International

File Number

Authorization Holder

Authorization Number

ITC-T/C-20180612-00109

Inmate Calling Solutions, LLC d/b/a
ICSolutions

ITC-214-20030312-00128

B.

Domestic

Applicants filed an application to transfer control of domestic section 214 authority in connection
with the proposed transaction. In light of the multiple applications pending before the Commission
with respect to this transaction and the public interest review associated with them, the domestic
transfer of control application is not subject to streamlined treatment.21

21

47 CFR § 63.03.

5