This article first appeared (yesterday) on TCPAland and is republished here with permission.

The post-ACA Int’l rulings on ATDS functionality continue to pile up at a clip of about one new ruling every 1-2 weeks.  The newest in the series is last week’s ruling out of the Northern District of Georgia – Maddox v. Cbe Group, No. 1:17-CV-1909-SCJ, 2018 U.S. Dist. LEXIS 88568 (N.D. Ga. May 22, 2018) (“Maddox”).  There, the court granted Defendant’s summary judgment motion on the basis its Manual Clicker Application (“MCA”) was not an ATDS.  But it did so in reliance on the 2003 FCC predictive dialer ruling, and based on its finding that making calls with the MCA required “human intervention”.

In reaching this conclusion, the court started by examining ATDS precedent and found a few things.  The court recognized that under the TCPA “the essential feature of an ATDS is that it uses a random or sequential number generator,” but that the FCC made “short-shrift” of that requirement (i.e. ignored it) in its 2003 ruling when it held that a system can qualify as an ATDS if it “relies on a given set of phone numbers.”

The court then turned its attention to ACA Int’l, finding first that the opinion is binding on the court.  But things got interesting from there because, instead of examining ACA Int’l’s analysis of ATDS functionality, the court limited its discussion to an observation that the D.C. Circuit had rejected the FCC’s interpretation of the term “capacity” in the 2015 ruling.  However, as we’ve covered before, ATDS capacity versus functionality are two distinct topics, with the key issue being functionality.  But the court stayed away from that issue, simply stating that “given” ACA Int’l, the court would follow the FCC’s prior 2003 predictive dialer ruling.

From there, the court found that under the 2003 ruling, “the focus is on whether the system can automatically dial a phone number, not whether the system makes it easier for a person to dial the number.”  Applying this rule, the court held that the defendant’s system – which required agents to click a button in order to initiate a call – was not an ATDS because it “requires human intervention,” and “does not use an kind of predictive or statistical algorithm to engage in predictive dialing or minimize waiting time.”

What’s interesting here is that this case involved the same defendant, and same MCA dialing system as Marshall v. Cbe Group, where the court held that the FCC’s prior predictive dialer rulings were no longer good law following ACA Int’l.  While the courts ultimately reached the same conclusion – that the MCA is not an ATDS – they diverged as to the issue of whether the FCC’s 2003 ruling remains good law after ACA Int’l.  This all goes to illustrate the continuing proliferation of inconsistencies in the law following ACA Int’l.  But it’s not all bad news – it seems that regardless of what standard a court applies, the MCA (and perhaps other similar click-to-dial applications), still don’t qualify as an ATDS.

PHOENIX, Ariz. — Teffia Inc. is proud to announce our national certification as a Women’s Business Enterprise (WBE) by the Women’s Business Enterprise National Council. Teffia is a Woman-Owned Small Business (WOSB), Economically Disadvantaged Woman-Owned Small Business (EDWOSB) and HUBZone certified company operating out of Phoenix Arizona.

“We are extremely proud to be a part of the WBENC organization. The WBE designation creates opportunities for small diversity businesses to play a major role in global organizations who understand the innovative and measurable benefits from a more diverse supply chain.” stated Anna Donnelly, President of Teffia Inc. “We also recognize the continuous commitment to supplier diversity that is involved by organizations and government agencies today, and we are excited to be able to support those needs. As one of only a few qualified Call Center and Business Process Outsourcing (BPO) companies in the US, we are anticipating significant growth this year through our WBE and HUBZone certifications.”

WBENC’s national standard of certification implemented by the Women’s Business Enterprise Council is a meticulous process including an in-depth review of the business and site inspection.  By including women-owned businesses among their suppliers, corporations and government agencies demonstrate their commitment to fostering diversity and the continued development of their supplier diversity programs. 

About Teffia Inc. – Teffia provides the additional, tangible benefit of working with some of the most brand sensitive world-class companies in the US including US Department of Education’s Student Loans collections and servicing. Our partnership connections include Government, Financial Services, Telecommunications, Utility and Retail industries. Our Operations teams are proactive and provide actionable insights into your business to provide the highest level of exceptional customer service to your customers.  Our comprehensive suite of solutions includes;

Customer Care and BPO

• General and Complex Customer service
• Customer Information Services (CIS)
• Customer inquiries
• Reservations and travel bookings
• Billing information
• Loyalty programs
• Social media management
• Customer Satisfaction Surveys
• Fraud management
• Back office work
• Help Desk and Technical support including; Internet access, service configurations, hardware/software and connectivity support

Receivables Management

• First Party collections
• Third Party collections
• US Department of Education Student Loans collections and servicing
• Early Out / Pre-Collect programs
• Skip & Collect programs
• Skip tracing
• Legal services

About WBENC

Founded in 1997, WBENC is the nation’s leader in women’s business development and the primary third-party certifier of businesses owned and operated by women with more than 13,000 certified Women’s Business Enterprises, 14 national Regional Partner Organizations, and over 300 Corporate Members. For more information, visit www.wbenc.org. 
Our principal owner and President, Anna Donnelly holds 15+ years’ industry experience and is committed to providing enhanced customer care performance.  Teffia has the technology and capacity to handle any project size we are located in Phoenix at:  455 N. 3rd Street, Suite 261, Phoenix, AZ 85004. 

Contact Us 

For additional information, we encourage you to visit the website at: www.teffia.com to learn more about how we can help you enhance your operations through our full suite of services. 

Anna Donnelly – President
anna.donnelly@teffia.com
(866) 241-4988 or Cell: (480) 239-6151 

John Stock – Vice President of Sales
john.stock@teffia.com
(866) 241-4988 or Cell: (251) 751-5130

 

Last Friday we learned that U.S. Court of Federal Claims Judge Thomas C. Wheeler granted the Department of Education’s (ED) motion to dismiss the case of FMS v. USA as moot. Read about that here. ED claimed the case was moot because it cancelled the Solicitation for unrestricted private debt collection services that were the subject of the protests. 

As justification for the cancellation, the Government offered two key points:

1. It has plenty of capacity to handle the volume of defaulted consumer accounts just by using the small business contractors who had already received an award to service defaulted student loans in October 2014.
2. It is planning a new strategy to head-off defaults by having servicers (companies like Navient, Nelnet, Great Lakes Educational Loan Services, and FedLoan Servicing) get more involved up front.

Last August, Federal Student Aid Fund (FSA), the part of ED that manages federal student loans, also cancelled a Solicitation for servicers and announced its “Next Generation Processing and Servicing” (NextGen). This marked the beginning of a major shift by ED in the way it expects to service its loans — from beginning to end. At the time, Dr. A. Wayne Johnson, who is running the NextGen program, said: 

“The FSA Student Loan Program represents the equivalent of being the largest special purpose consumer bank in the world. To improve customer service, we will take the best ideas and capabilities available and put them to work for Americans with student loans. When FSA customers transition to the new processing and servicing environment in 2019, they will find a customer support system that is as capable as any in the private sector. The result will be a significantly better experience for students – our customers – and meaningful benefits for the American taxpayer.”

The 2019 date appears to be timed to coincide with the expiration of the current servicer contracts (these are the ones that were the subject of the new Solicitation that was cancelled in conjunction with the NextGen announcement).

In addition to getting all servicers on one platform (the Navients, Nelnets, etc.), industry experts noted that the system design revealed in December 2017 included a default management module as well. It seemed, though, that this module would be years away from becoming a reality, as it hasn’t yet been the subject of a technology solicitation.

Protesting collection agencies claim three things in relation to all of these changes:

1. This is a huge project, to say the least. It seems unlikely that ED’s timeline will not experience delays.
2. Increased efforts in the past to prevent default have not worked, so without additional details it’s difficult to conclude the future would be any different.
3. The data shows that the number of students in default has increased by 109% from Q4 2013 to Q4 2017, so it seems improbable that the existing small business contractors could handle the volume.

Here is what ED’s data shows:

This data shows that from Q4 2013 to Q4 2017 there was a 28% increase in the number of borrowers in the total direct federal student loan program. The same period brought a decrease of 14% in students in (or just out of) school, a 57% increase in the number of borrowers in repayment, a 24% increase in those in forebarance or deferment, and a 109% increase in the number of those in default. This is the period during which the 2009 unrestricted contract for private debt collectors expired. The 2014 award increased the number of small business contractors, but five large agencies also received extensions — and all had been receiving accounts until an injunction in May 2017.

The large collection agencies that are now expected to file a new bid protest will say, in part, that ED’s decision to cancel the Solicitation for unrestricted private debt collectors flies in the face of logic, given the drastic increase in the number of defaulted accounts, even with the increase in small business contractors.

Meanwhile, the Washington Post reported last Friday that ED expects to have the servicers handle the specialized function of default management. I suppose anyone can learn anything but many will tell you that managing past due accounts is quite different than sending statements, processing payments and answering questions on inbound calls. 

 

CARROLLTON, Texas — During May 2018, The CMI Group (CMI) conducted a game drive to raise donations for Ronald McDonald House of Dallas.

The CMI Group and its employees donated over 50 board games, card games, and puzzles for the children and families at Ronald McDonald House and for their family rooms in various local hospitals. CMI is gratified to be able to provide a means to allow the children and their families served by Ronald McDonald House of Dallas to enjoy fun pastimes together during their hospital stays. 

About Ronald McDonald House of Dallas 

In an effort to lessen the burden, reduce stress, keep the family intact, and enhance the quality of life for these families, Ronald McDonald House of Dallas provides temporary housing in a caring home-like atmosphere.  Ronald McDonald House program was built on the simple idea that nothing else should matter when a family is focused on healing their child – not where they can afford to stay, where they will get their next meal, or where they will lay their head at night to rest.  Ronald McDonald House of Dallas is keeping families together, inspiring strength, and giving love and support to families whose children are receiving essential medical care. For more information, visit https://rmhdallas.org/. 

About The CMI Group

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Founded in 1985, CMI is a full-service receivable management firm providing leading-edge solutions to customers nationwide. Through its subsidiaries, CMI delivers innovative first-and third-party revenue cycle, accounts receivable management, and BPO solutions resulting in enhanced operational efficiency and increased revenue for its customers. Serving a multitude of industries, CMI has headquarters in Carrollton, TX, with satellite offices in Dallas and Rochester, MN. For more information, visit www.thecmigroup.com.

CALABASAS, Calif. — Cedar Financial is proud to share a recap of its recent 10^th Annual Women’s Empowerment Build. 

At Cedar Financial our foundation of “Putting People First” stretches far beyond our office walls. Our Calabasas team has had the privilege of being involved with a few truly inspiring charities, allowing us the chance to give back to the community and help spread awareness for some incredible foundations. 

Over the weekend of May 12th, 2018 – Cedar Financial joined forces with Homes 4 Families at the Santa Clarita Veteran Enriched Neighborhood for their 10th Annual Women’s Empowerment Build. During this amazing event, our staff was able to contribute to 24 new homes being built for low income families and veterans – all while appreciating and recognizing the power of women coming together. The event focused on empowering women and acknowledging the strength, independence, and drive from females in our local community.

Homes4Families

This organization has been instrumental in raising awareness for families living in poverty, fair treatment for veterans, and helping build self-esteem for individuals to look towards a brighter future with confidence and determination. Their current services include The Enriched Neighborhoods program, Promoting Self-Sufficiency, and Serving Military Children.

“Homes 4 Families’ mission is to build resiliency, economic growth, neighborhoods, and homes for veteran families. Homes 4 Families empowers low-income veterans and their families to enter the middle class through affordable, full-equity homeownership and sustainable housing combined with holistic services that build resiliency, self-sufficiency and economic growth.”

Our WE Build Experience

Cedar Financials Operations Manager, Rachel Moaddab shares, “It was a great experience getting to work beside volunteers who already live in or are planning to live in these complexes. Our team focused mainly on building the structures and framing of these new homes. During our lunch break, coordinators gave us more details about the cost analysis on how beneficial and imperative it is to get voluntaries to help with these builds.

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While our team helped with the framing, HFH staff explained that without volunteers, the cost of these services can reach up to $75,000-$120,000 for the day. Johana Hernandez, a medical collector with Cedar Financial added, “one of the veterans we got to work beside explained she would be able to purchase her home for $296K now, instead of the market price of $400k, because of all the volunteer work put in.” Head to the Homes 4 Families website to see how you can help today. 

Homes4Families:  http://www.homes4families.org/

Habitat for Humanity: http://www.habitatla.org/

Cal Veteran Affairs: https://www.calvet.ca.gov

For more information please visit our website: www.CedarFinancial.com

This afternoon Judge Thomas C. Wheeler of the U.S. Court of Federal Claims granted the Department of Education’s (ED) motion to dismiss the case of FMS v. USA as moot, and lifted the February 26, 2018 preliminary injunction that prevented ED from recalling in-repayment accounts.

Here is an excerpt from the Order published today:

For reasons to be explained in a more substantive Opinion in the coming days, the Court GRANTS the Government’s motion to dismiss, LIFTS the February 26, 2018 PI, DENIES Plaintiffs’ motions for leave to file supplemental pleadings, and DENIES Performant’s motion for partial dismissal as MOOT. The Clerk is directed to dismiss Plaintiffs’ complaints without prejudice. No Costs. For the sake of judicial continuity and efficiency, any new protests that may be filed challenging ED’s decision to cancel the solicitation should indicate that they are related to the FMS Investment Corp. line of cases.

For those who need the incredibly short recap…This all started in 2014 when the five-year 2009 contract ended, and new large-firm awards were delayed. Eventually, contracts were awarded in 2016 to seven large companies, down from 17 on the previous contract. This led to dozens of protests by firms that believed the process was flawed and unfair. So began Chapter Two of the matter, with a “re-do” of the solicitation, which resulted in awards to just two large companies. This led to more protests, and finally… nothing. No large company awards at all, as ED cancelled the whole solicitation on May 3, 2018, rescinded the contract awards from the two companies, and filed a motion to dismiss the litigation. And so began Chapter Three, with 13 parties opposing that motion.

For those who want to review all of the details, click here for the full coverage of the Department of Education collection contract on insideARM.

insideARM Perspective

True to form, Judge Wheeler made a prompt decision following the deadline for filing motions, which was only two days ago. He says there will be a more substantive explanation of his thinking in the coming days, so we’ll look forward to that.

For now, I would expect those firms who still hold in-repayment accounts as part of the 2015 Award Term Extensions to receive letters recalling those accounts as early as next week.

I would also expect to see a new round of litigation filed; at least one firm — Automated Collection Services, Inc. (ACSI) — promised as much in their filing on Wednesday.

As CEO of one of the nation’s leading Accounts Receivable agencies, Gordon Beck goes to great lengths to ensure his collections agents are happy. With the implementation of an Intelligent Virtual Assistant, Diversified Consultants will be dramatically reducing the amount of time their agents spend on non-revenue generating transactions.

 

To learn more about how Diversified Consultants is supercharging their agent productivity with Artificial Intelligence, download the full interview here.

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There were three filings yesterday in the case of FMS v. USA (Department of Education, or ED).

1. ED’s reply in support of its motion to dismiss the case as moot and to lift the February 2018 preliminary injunction preventing the recall of “in repayment” accounts
2. An amended complaint by plaintiff Progressive Financial Services, Inc. (Progressive), asserting additional grounds of protest relating to ED’s actions
3. A reply by plaintiff Pioneer Credit Recovery, Inc. (Pioneer) to various parties’ requests for an extension of the February 2018 preliminary injunction preventing the recall of in-repayment accounts

The Department of Education Response

As insideARM reported on May 21, ten firms filed opposition to ED’s motion to dismiss the case as moot (given that ED decided to cancel the entire Solicitation for unrestricted private debt collectors). The firms all basically argued that the move – based on a new operational strategy that is as of yet unimplemented — was irrational.

Yesterday ED responded to the opposition, saying that their arguments are premature and unfounded, and that their claims should be addressed via new protests of the cancellation. Further, ED argues that any such protests, however, cannot cure the claims that the cancellation of the Solicitation rendered moot.

ED claims that the gross data about rising student debt defaults cited by those opposing their motion is irrelevant until new protests are filed and reviewed against an administrative record specific to the decision to cancel. ED says the record supporting the decision will show that the arguments are baseless, and that the contracting officer determined that,

“[t]here is presently more than sufficient capacity, through at least 2024 to perform any Debt Collection Services that may be needed. The 11 active small business contracts are capable of handling 750,000 new accounts per month. The contracting officer estimated the current need, even excluding the eventual impact from the enhanced service provider(s), to be approximately 120,000 new accounts per month… This leaves a cushion of over 600,000 accounts per month while ED transitions to the enhanced servicer(s).”

ED further claims that the plaintiffs cite no case law, and no case law exists, to support a finding that the claims directed at the prior award decision are not moot, so those claims should be dismissed.

As to the matter of the recall of in repayment accounts, ED says it is willing to voluntarily stay any recall subject to the injunction until June 30, 2018. A notice of intent to recall the accounts on that date would be sent to the relevant PCAs on June 15, 2018.

Progressive’s Amended Complaint

Progressive argues that because it has requested leave to file a supplemental complaint, the Government’s motion to dismiss the original complaint is now moot. Although ED argues that the Court no longer has jurisdiction in the case because the subject (the Solicitation) has been cancelled and any opposition must be in the form of a new bid protest, Progressive argues that the Court does retain jurisdiction. Further, Progressive asserts that because ED’s decision to cancel the Solicitation is improper, the Court retains jurisdiction over Progressive’s entire protest. Their argument states,

“Progressive’s protest grounds concerning the evaluation of its proposal and the awardees’ proposals remain viable (Counts I-III, and VII), and should be decided by the Court in accordance with the Rules of this Court. However that determination cannot exist until the Court first determines whether ED’s cancellation decision was reasonable. If the Court grants relief to Progressive under Count IX of its Supplemental Complaint, the effect would be a return to the status quo that existed before ED made the decision to cancel the Solicitation, namely, a flawed evaluation and improper awards to Performant and Windham. If Counts I-III, and VII of Progressive’s Complaint are dismissed now, and Progressive prevails under Count IX, Progressive will have to re-file its protest to obtain full relief. 

Accordingly, it is premature to dismiss Counts I-III and VII at this time, before the Court determines whether ED’s cancellation decision was proper. Upon prevailing under Count IX, Progressive will seek relief in the form of an award to Progressive, as an offeror who offered a superior proposal, or, in the alternative, will seek an Order from the Court requiring ED to re-evaluate the proposals, proceed with the procurement, and make an award as required by the Solicitation and federal law. Thus, the interests of judicial economy and efficiency weigh against the outright dismissal of Progressive’s underlying protest grounds as moot, without further analysis regarding the proprietary and reasonableness of ED’s cancellation decision.”

Pioneer Responds to Requests for Extension of the Preliminary Injunction

First, a bit of background on Pioneer’s positioning in the case. The company was one of five contractors that was suddenly terminated by ED in February 2015. This launched the first round of litigation in the unrestricted contract debacle.

Meanwhile, the new contract decision process continued. When the first round of awards was finally announced on December 9, 2016, Pioneer did not make the list.

So, back to the wrongful termination appeal related to the old contract…ultimately, two of the five firms – Enterprise Recovery Systems, Inc. (now Alltran Education) and Pioneer — won their appeal, and received Award Term Extensions (ATEs) on April 28, 2017.  

Now, back to Pioneer’s the current response to other plaintiff’s requests for an extension of the February 26, 2018 preliminary injunction. That injunction prevented the recall of in-repayment accounts that are with firms that received ATEs in 2015 (when the 2009 contract ended) – not the ATE held by Pioneer.

Pioneer argues that the Court should not extend the injunction, but rather should dissolve it because the protests and all relevant facts upon which they were based are no longer relevant. “The February 26 PI was based on specific alleged errors regarding the evaluation of proposals and ED’s recalling of accounts in light of its new awards…The questioned data is no longer operative because ED has cancelled the procurement and made clear that it will not under any circumstances rely on the data that the Court questioned in its February 26 PI decision.”

insideARM Perspective

Judge Wheeler has typically provided swift decisions following filing deadlines. All we can do is watch.

If you want more history on the case, see our full archive here.

Transworld Systems Inc. (TSI) announced yesterday that it has completed a comprehensive financial restructuring of the Company’s debt and equity.

According to the announcement, the recapitalization was implemented via a voluntary, out-of-court transaction and did not impact TSI’s customers, operations, facilities, or employees.

The restructuring decreased the Company’s outstanding debt by approximately $460 million, or 91%, through (i) an exchange of the Company’s 9.5% Senior Notes due 2021 (the “Notes”) for new debt and new common equity, (ii) a partial repayment and extension of the Company’s revolving credit facility, and (iii) a $39 million equity capital injection into the Company.

“The successful completion of this transaction provides TSI with significant financial flexibility to invest in the business to drive growth,” said Joe Laughlin, CEO of TSI.  “We are pleased to partner with Clearlake Capital, Platinum Equity and our other new equity holders.  I would like to thank our customers, employees, vendors and regulators for their patience and support as we moved through this process.”

TSI is an analytics-driven provider of accounts receivable management, healthcare revenue cycle, and loan servicing solutions.

If you haven’t yet learned about efforts by carriers or software providers to block or label automated calls to consumers, you soon will. Or at least you certainly should. When you dig in, you’ll learn that there are more than 500 application (app) providers, which consider themselves ‘editorial services,’ and four major carriers (though there are many more smaller ones) which have recently been given permission by the Federal Communications Commission (FCC) to a) not deliver certain calls and b) provide their customers with the ability to opt-in to additional blocking/labeling services to help avoid fraudulent or unwanted calls.

All of this has left the heads of legitimate call originators spinning. Recently, Verizon posted guidance for these firms on its website. The carrier suggests the following best practices, which can help avoid being blocked or inappropriately labeled.

Follow practices known to constitute good call center hygiene.

1. Provide a consistent, real, and user-dialable telephone number with every call you make.  Calls with a calling party number that is invalid or not assigned to the caller are often associated with spam. You may want to consult your account representative at your service provider if you are unsure about this best practice.
2. Do not “random wardial” and do not call unassigned numbers frequently. Unreasonable answer and completion rates are often associated with spam.
3. Align the context and content of your calls to a specific traceable calling party number for the duration of that number’s assignment to a particular campaign.  Avoid using the same telephone number for multiple purposes. For example, using the same number for marketing, surveys, and support callbacks would typically increase the likelihood of being categorized as spam.  It is recommended that numbers that are re-assigned for other purposes or allocated to other providers go through a 45-day waiting period.
4. Avoid unusual spikes in traffic volumes, and follow and document your expected and normative call pattern description (e.g. 10,000 caller per day).
5. Comply with “Do Not Call” lists and other TCPA requirements, and provide a number / contact information that called parties can use to prosecute or report any alleged violations of law.
6. Provide and document a consistent Calling Name profile that matches the context of the calls you are making and your callback information.

Use common sense to minimize the risk that consumers report your calls as spam or file complaints about you with government agencies.

1. Legitimate calling parties should never use abusive language, call too frequently, have perceptible delays in the quality or reliability of connection, or make unsolicited calls at odd hours.
2. Legitimate callers should always provide clear identification of the calling party, along with clear-and-easy opt-out directions.

Also of note is that Verizon recently announced it was the first to release robocall screening assist for landlines. (emphasis added)

As Amy Perkins — Chief of Content for insideARM — shared in her recent article, Call Blocking/Labeling: Big Impact, But Little Understanding, this matters to collection and recovery leaders because:

• If you contact customers via the telephone, you will be impacted (the impact may have already started).
• If your calls are inappropriately flagged as spam calls, they may be blocked by carriers or by mobile phone apps.
• If your calls aren’t blocked, but are mislabeled (the analytics companies will decide how legitimate calls are labeled) on the caller ID, you may not get through to your customers.
• If you take no action, there’s a high probability you will see a sharp decline in RPC rates and your customers will be in the dark.

insideARM Perspective

Most legitimate collection operations likely already comply with most of the above recommendations (although some of us in the industry have also been working to educate carriers and app developers about the nuances of calling patterns in collections). However the toughest challenge may be the last item – “Legitimate callers should always provide clear identification of the calling party…” …except if you are a debt collector whose name might give that away.

Regulators, please take note: the requirements of the Fair Debt Collection Practices Act (from 1977) says that collectors may not communicate about a debt with a third party, except in limited circumstances. The definition of “communicate” has been very broadly defined by the courts over the years and has led to volumes of litigation related to leaving voicemail messages (among other things), because standard voicemail technology required a consumer to listen to a recording in the open, where others might hear. 

So, consumers are demanding to know who is calling them and why. Carriers and hundreds of software companies have jumped into the fray to help — with the full encouragement of the FCC and other regulators. But providing this information to consumers in the case of debt collection is likely considered a violation of the FDCPA (there’s a HIPAA issue too, as it relates to healthcare accounts, but we’ll leave that for another time). It’s time to revisit this broad definition of third party disclosure and give consumers the information they want.

insideARM will be covering this topic in depth at the upcoming First Party Summit in Dallas, June 4-6.