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Comment Sought on Domestic 214 Transfer of T-NETIX,T-NETIX Telecom-STI

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Released: March 28, 2013


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 13-578

Released: March 28, 2013





WC Docket No. 13-79

Comments Due: April 11, 2013
Reply Comments Due: April 18, 2013

On March 18, 2013, Connect Acquisition Corp. (Connect), T-NETIX, Inc. (T-NETIX), T-NETIX
Telecommunications Services, Inc., (T-NETIX Telecom), Securus Technologies, Inc. (STI), and Securus
Investment Holdings, LLC (Securus Investment) (collectively the Applicants), filed applications, pursuant
to section 63.03 of the Commission’s rules,1 for the transfer control of T-NETIX, T-NETIX Telecom and
STI to Securus Investment.
STI, T-NETIX and T-NETIX Telecom, all Delaware corporations, are privately held and wholly-
owned subsidiaries of Securus Technologies Holdings, Inc. (STHI). T-NETIX provides inmate calling
services and public payphone services, which it provides principally to or at confinement facilities, in
Arkansas, Maryland, Oregon, Pennsylvania, South Carolina, and Texas. T-NETIX Telecom is authorized
to provide domestic interstate services as a non-dominant carrier. STI provides interstate services as part
of inmate calling services and public payphone services, which it provides principally to, or at,
confinement facilities. STHI is a wholly-owned subsidiary of Securus Holdings, Inc. (Securus Holdings),
a Delaware corporation and subsidiary of Connect. STHI, Securus Holdings, Securus Investment, and
Connect, a Delaware limited liability company, are not providers of telecommunications services.
Securus Investment, a Delaware limited liability company, formed Connect Merger Sub, Inc.
(Connect Merger Sub) a Delaware corporation, solely for the purpose of this transaction. At the time the
transaction is consummated, approximately 95.3 percent of the interests in Securus Investment will be
indirectly held by Securus Special Investments, LLC (SSI), a Delaware limited liability company. ABRY
Partners VII, L.P., a Delaware limited partnership, will hold a 66.88 percent equity interest in SSI. SSI
will be controlled by ABRY Partners VII, L.P., an affiliate of ABRY Partners, a Boston-based private
equity investment firm focused solely on media, communications, business, and information services
investments. HarbourVest Partners 2012 Direct Fund LP and Redoak Investments LLC, both U.S.

1 47 C.F.R § 63.03; see 47 U.S.C. § 214. Applicants are also filing applications for transfer of control associated
with authorization for international services. Any action on this domestic section 214 application is without
prejudice to Commission action on other related, pending applications.

entities, each hold a 15.43 percent interest in SSI. HarbourVest Partners, LLC, a Delaware limited
liability company is the managing member of HarbourVest Partners 2012 Direct Fund LP and Redoak
Investments LLC and is owned by nineteen individuals, none of whom control the entity. After
consummation of the proposed transaction, STHI and its subsidiaries will become affiliated with other
entities that provide regulated telecommunications services.2
Pursuant to the Asset Purchase Agreement among Connect, T-NETIX, T-NETIX Telecom,
Securus Technologies, Inc., Securus Investment, and Connect Merger Sub, Connect Merger Sub will
merge into and with Connect. Upon completion of this merger, the separate existence of Connect Merger
Sub will end and Connect will be the surviving corporation. As a result, STHI and its operating
subsidiaries will become subsidiaries of Securus Investment. Applicants assert that the proposed
transaction is entitled to presumptive streamlined treatment under section 63.03(b)(2)(i) of the
Commission’s rules and that a grant of the application will serve the public interest, convenience, and
Domestic Section 214 Application Filed for the Transfer of Control of the Operating
Subsidiaries of Securus Technologies Holdings, Inc. to Securus Investment Holdings,
LLC, WC Docket No. 13-79 (filed Mar. 18, 2013).


The transfer of control identified herein has been found, upon initial review, to be acceptable for
filing as a streamlined application. The Commission reserves the right to return any transfer application
if, upon further examination, it is determined to be defective and not in conformance with the
Commission’s rules and policies. Pursuant to section 63.03(a) of the Commission’s rules, 47 CFR §
63.03(a), interested parties may file comments on or before April 11, 2013, and reply comments on or
before April 18, 2013.
Pursuant to section 63.52 of the Commission’s rules, 47 C.F.R. § 63.52,
commenters must serve a copy of comments on the Applicants no later than the above comment filing
date. Unless otherwise notified by the Commission, the Applicants may transfer control on the 31st day
after the date of this notice.4
Pursuant to section 63.03 of the Commission’s rules, 47 CFR § 63.03, parties to this proceeding
should file any documents in this proceeding using the Commission’s Electronic Comment Filing System

In addition, e-mail one copy of each pleading to each of the following

1) Tracey Wilson, Competition Policy Division, Wireline Competition Bureau,;
2) Dennis Johnson, Competition Policy Division, Wireline Competition Bureau,;
3) David Krech, Policy Division, International Bureau,; and
4) Jim Bird, Office of General Counsel,

2 See applications for a complete list of affiliated entities.
3 47 C.F.R. §63.03(b)(2)(i).
4 Such authorization is conditioned upon receipt of any other necessary approvals from the Commission in
connection with the proposed transaction.

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 or call the
Consumer & Governmental Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (tty).
The proceeding in this Notice shall be treated as a “permit-but-disclose” proceeding in
accordance with the Commission’s ex parte rules.5 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 the presentation of data or arguments
already reflected in the presenter’s written comments, memoranda or other filings in the proceeding, 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 C.F.R. § 1.1206(b). Participants in this proceeding should familiarize
themselves with the Commission’s ex parte rules.
For further information, please contact Tracey Wilson at (202) 418-1394 or Dennis Johnson at
(202) 418-0809.
- FCC -

5 47 C.F.R. §§ 1.1200 et seq.

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