
ATTORNEYS
AT
LAW
,~
CARS
~,
~
JORDEN
BURT
June
13,
2014
Roxann
M.
Ryan,
Esquire
Iowa
Department
of
Public
Safety
Oran
Pape
Building
215
East
7th
Street
Des
Moines,
Iowa
50319-0049
Re:
TF
Wireless
Products
Petition
for
Declaratory
Statement
Dear
Ms.
Ryan:
215
S.
Monroe
Street
~
Suite
500
Tallahassee,
Florida
32301-1866
P.O.
Drawer
190
~
Tallahassee,
Florida
32302-0190
850.224.1585
~
fax
850.222.0398
www.CFJBLaw.com
Atlanta
Hartford
Los
Angeles
Miami
New
York
Orlando
St.
Petersburg
Tallahassee
Tampa
Washington,
DC
West
Palm
Beach
VIA
ELECTRONIC
MAIL
Roxann.
rvanCa~iowa.c~ov
Thank
you
for
the
opportunity
to
provide
supplemental
information
relating
to
the
Petition
for
Declaratory
Statement
submitted
on
behalf
of
TF
Wireless
Products,
LLC.
During
the
public
hearing
held
on
Tuesday,
June
3,
2014,
there
appeared
to
be
some
confusion
regarding
statements
made
in
the
Amended
Petition.
In
order
to
provide
clarification,
we
are
submitting
a
Second
Amended
Petition
for
Declaratory
Statement
for
consideration
by
the
Department.
One
of
the
attendees
at
the
June
3`
d
public
hearing
noted
that
products
similar
to
the
TF
Wireless
device
are
currently
on
sale
at
retail
stores
in
Iowa.
Following
up
on
that
comment,
we
researched
similar
devices
that
are
currently
available
through
three
"big
box"
retail
stores
—
Lowe's,
Home
Depot,
and
Walmart
—all
of
which
have
locations
in
Iowa.
A
summary
description
of
the
various
devices
is
attached
hereto
as
Exhibit
A.
I
am
also
attaching
photos
of
each
of
the
devices,
including
TF's
HomeAlert,
as
Exhibit
B.
We
noted
that,
in
some
instances,
the
store's
website
indicated
that
a
particular
device
could
not
be
shipped
to
certain
states.
However,
Iowa
was
not
identified
as
a
prohibited
state
for
any
of
the
devices.
We
also
consulted
the
Iowa
Department
of
Public
Safety's
website
for
a
list
of
the
currently
licensed
alarm
system
contractors
and
installers
in
Iowa.
Neither
the
three
retail
stores
that
sell
the
similar
devices
nor
the
companies
that
produce
the
devices
are
identified
as
licensed
entities.
TF's
position,
as
stated
in
its
petition,
neither
it
nor
any
of
the
producers
of
the
devices
currently
being
sold
in
Iowa
are
engaged
in
alarm
system
contracting
or
installation
and,
as
a
consequence,
are
not
required
to
obtain
a
license
from
the
Department.
However,
as
was
suggested
by
the
speaker
during
the
public
hearing,
if
the
Department
were
to
determine
that
TF
Wireless
must
obtain
an
alarm
system
contractor
license
before
offering
its
device
for
sale
in
Iowa,
the
producers
of
each
of
the
devices
already
being
sold
in
Iowa
must
also
be
required
to
obtain
licenses.
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