Loss Prevention For Direct Marketers: Tips, Tools, and Taboos

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• Loss Prevention For Direct Marketers Tips,
  Tools, and Taboos

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Topics

• Perfect Storm on the Horizon Reaching Consumers
  without violating expectations of privacy.
• Junk Fax litigation A cautionary tale for
  marketers
• Adware
• Privacy policies and data security
• Safer marketing terrain, including Blogging and
  E-mail (yes, e-mail!)
• Transferring risk the American Way Blame someone
  else!

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Cutting through the ClutterPractical Challenges
for Direct Marketers

• U.S. companies sent 35 billion pieces of direct
  postal mail in 1980, 64 billion pieces in 1990,
  90 billion pieces in 2000, and 100 billion pieces
  in 2005. Thats more than 300 pieces of bulk mail
  for every man, woman, and child! (U.S. Postal
  Service)
• The average American is exposed to 247 commercial
  messages each day. (Consumer Reports)
• Demonstrating return on investment through
  consumer response.

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Increasing consumer response requires more and
more information about the consumer

• Timing Delivering an offer when the consumer is
  most likely to consummate a purchase
• Relevance Offer responds to unique need
• Personalized Offer targets recipient

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Legal challenges in reaching consumers

• Do you market diaper coupons for families who
  just had a newborn?
• Do you market adult diaper coupons to individuals
  who just had surgery on their colon?
• Where do you draw the line?

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Privacy The next battleground

• As technology improves at a rapid pace and more
  information is compiled and made available to
  businesses to improve consumer response and
  return on investment, the more businesses will
  become targets of lawsuits.
• Like the word freedom, privacy means so many
  different things to so many different people and
  has become the underlying rationale for new laws
  and policies.

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Lessons Learned from Fax Advertisement Litigation
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What do you see?
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How the marketer and/or business owner sees it.

• A means of communicating good offers to valued
  customers.
• Targeted marketing directed only to those who
  would be interested in offer or product.
• Exciting and new advanced technology enabling
  quicker and cheaper marketing.

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What does a plaintiffs lawyer see?
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Fax advertisement verdicts

• AMF Bowling Centers settled for 1 million in
  cash and 1.5 million in coupons.
• Hooters hit with 11.9 million verdict that was
  upheld on appeal.
• Fax.com settles for 6 million
• APO Health settles for 4.5 million

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• Ameriguard, Inc., v. Univ. of Kansas Med. Center
  Research Inst., Inc., 2007 TCPA Rep. 1532 (2007)
  (affirmed)
• Altman v. Aqua Vie Beverage Corp., 2005 TCPA Rep.
  1329 (2005) (order granting plaintiff MSJ)
• Altman v. Inside Edge, Inc., 2004 TCPA Rep. 1291
  (2004) (order denying def. MSJ, granting pltf.
  MSJ)
• Americom Imaging Sys. Inc., v. Diamond Waste Ind.
  III, Inc., 2004 TCPA Rep. 1273 (2004) (order
  denying def. MTD.)
• Americom Imaging Sys., Inc. v. Texas Computer
  Resale, LLC, 2003 TCPA Rep. 1184 (2003) (order
  denying def. MTD)
• Americom Imaging Sys., Inc. v. Texas Computer
  Resale, LLC, 2004 TCPA Rep. 1367 (2004) (order
  denying def. MTD)
• Americom Imaging Sys., Inc. v. Trash Taxi of St.
  Louis, LLC, 2004 TCPA Rep. 1272 (2004) (order
  denying def. MTD.)
• Ameriguard, Inc., v. Univ of Kansas Ed. Ctr.
  Research Inst., Inc., 2006 TCPA Rep. 1491 (2006)
  (MTD granted)

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• BMR Ind., Inc. v. Central Missouri Pizza, Inc.,
  2002 TCPA Rep. 1077 (2002) (injunction to
  preserve records)
• Brentwood Travel Serv., Inc. v. Ewing d/b/a
  Carousel fo Stitches, 2002 TCPA Rep. 1063 (2002)
  (order denying def. MTD)
• Brentwood Travel v. Dana Capital Group, Inc.,
  2007 TCPA Rep. 1536 (2007) (Order denying PO)
• Brentwood Travel, Inc. v. Annex Computers, Inc.,
  2001 TCPA Rep. 1046 (2001) (order granting Pl.
  MSJ and injunction issued)
• Brentwood Travel, Inc. v. Lancer, Ltd., 2001 TCPA
  Rep. 1018 (2001) (order den. Def. mtn. to
  dismiss)
• Brentwood Travel, Inc. v. Lancer, Ltd., 2001 TCPA
  Rep. 1019 (2001) (order granting Pl. MSJ)
• Brodeur v. Lou Fusz Automotive Network, Inc.,
  2005 TCPA Rep. 1412 (2005) (Order denyiong def.
  MSJ)
• Brodeur v. Swan Fin. Corp., 2006 TCPA Rep. 1437
  (2006) (order finding duty to defend)

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• CBI.COM, Inc., v. Gross, 2005 TCPA Rep. 1372
  (2005) (order denying def. MTD)
• Clean Carton Co. v. 24 Hour Fitness USA, Inc.,
  2003 TCPA Rep. 1305 (2003) (order denying class
  cert.)
• Clean Carton Co. v. Prime TV, LLC, 2004 TCPA Rep.
  1294 (2004) (order granting class cert.)
• Clean Carton Co., Inc. v. Constellation 3D, Inc.,
  2002 TCPA Rep. 1055 (2002) (order denying Def.
  mtn. to dismiss re First Amendment)
• Clean Carton Co., Inc. v. Constellation 3D, Inc.,
  2002 TCPA Rep. 1056 (2002) (order denying MTD on
  third party acts)
• Clean Carton Co., Inc. v. Robert Reason, 2002
  TCPA Rep. 1102 (2002) (order and judgment
  granting pltf. MSJ)
• Coleman v. Am. Blast Fax, Inc., 2001 TCPA Rep.
  1021 (2001) (order and judgment)
• Coleman v. Am. Blast Fax, Inc., 2000 TCPA Rep.
  1022 (2000) (order denying Def. JOP.)
• Coleman v. Real Estate Depot, Inc., 2001 TCPA
  Rep. 1026 (2001) (order granting Pl. MSJ)
• Coleman v. Varone, 2001 TCPA Rep. 1030 (2001)
  (order denying Def. mtn to dismiss.)
• Colt Ind., Inc. v. Ernie Patti Pontiac-GMC, Inc.,
  2002 TCPA Rep. 1097 (2002) (order denying def.
  MTD on 1st amendment grounds and denying stay)

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• Davis, Keller, Wiggins, LLC. v. JTH Tax, Inc.,
  2001 TCPA Rep. 1040 (2001) (order denying Def.
  mt. to dismiss)
• Franklin County Express, LLC v. Global Comm.,
  Inc., 2002 TCPA Rep. 1099 (2002) (order denying
  def. MTD)
• Fun Svcs. of Missouri, Inc. v. Drury Inns, Inc.,
  2003 TCPA Rep. 1095 (2003) (order denying costs
  on remand motion)
• Fun Svcs. of Missouri, Inc. v. Drury Inns, Inc.,
  2002 TCPA Rep. 1098 (2002) (order remanding to
  state court)
• Gans, v. Leiserv, Inc. d/b/a Brunswick Four
  Seasons Bowl, 2003 TCPA Rep. 1092 (2003) (order
  granting pl. mtn. to remand)
• Gans, v. Leiserv, Inc. d/b/a Brunswick Four
  Seasons Bowl, 2004 TCPA Rep. 1354 (2004) (Final
  judgment and class certification)
• Harjoe v. Colonial Life Accident Ins. Co., 2002
  TCPA Rep. 1064 (2002) (order granting Pl. MSJ)
• Harjoe v. Colonial Life Accident Ins. Co., 2002
  TCPA Rep. 1065 (2002) (trial de novo order
  granting Pl. MSJ)

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• I Dream Solns., Inc. v. Ellsworth, Inc., 2002
  TCPA Rep. 1071 (2002) (order denying Def. mtn. to
  dismiss)
• Information Mgmt. Solns., Inc. v. Data Support.
  Sys., Inc., 2003 TCPA Rep. 1330 (2003) (order
  denying def. MTD)
• J.C. Corporate Management, Inc. v. Resource Bank,
  2005 TCPA Rep. 1384 (2005) (order granting
  remand)
• Joseph-Cowan v. Royal Gate Dodge, Inc., 2006 TCPA
  Rep. 1540 (2006) (Class final judgment)
• Lander and Berkowitz, P.C., v. Transfirst Health
  Svsc., Inc., 2005 TCPA Rep. 1366 (2005) (order
  granting remand)
• Little v. Brinker Missouri, Inc., 2005 TCPA Rep.
  1382 (2005) (order granting class cert.)
• Little v. Drury Inns, Inc., 2005 TCPA Rep. 1421
  (2005) (Order denying MTD re SOL.)
• Margulis v. 1-800-GOT-JUNK?, LLC, 2006 TCPA Rep.
  1470 (2006) (Order deny MTD class action)
• Margulis v. Benson, d/b/a/ Nat'l Assoc. of Ind.
  Landlords, Inc., 2004 TCPA Rep. 1306 (2004)
  (order denying def. MTD)
• Margulis v. Fairfield Resorts, Inc., 2004 TCPA
  Rep. 1292 (2004) (order denying def. motion to
  compel)
• Margulis v. PM Consulting, Inc., 2003 TCPA Rep.
  1094 (2003

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• Margulis v. PM Consulting, Inc.,, 2003 TCPA Rep.
  1248 (2003) (order affirming trial decision)
• Margulis v. VoicePower Telecom., Inc., 2001 TCPA
  Rep. 1023 (2001) (order denying Def. mtn. to
  dismiss)
• Marquis Fin. Corp. v. Salter, 2004 TCPA Rep. 1332
  (2004) (order debying def. MTD)
• Micro Eng. v. St. Louis Ass'n of Credit Mgmt.,
  Inc., 2002 TCPA Rep. 1080 (2002) (order denting
  Def. mtn. to dismiss)
• Micro Eng. v. St. Louis Assn of Credit Mgmt.,
  Inc., 2002 TCPA Rep. 1081 (2002) (order denying
  Def. mtn. to sever)
• Micro Eng., Inc., v. Hotel Reservations Network,
  Inc., 2003 TCPA Rep. 1091 (2003) (order allowing
  motion to intervene)
• Nat'l Ed. Acceptance, Inc. v. Community Lending
  Svc., Inc., 2002 TCPA Rep. 1101 (2002) (form
  order denying def. MTD)
• Nat'l Ed. Acceptance, Inc. v. Expiry Corp., 2002
  TCPA Rep. 1096 (2002) (order denying def. MTD)
• Nat'l Ed. Acceptance, Inc. v. Smartforce, Inc.,
  2002 TCPA Rep. 1057 (2002) (order and judgment)

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• Nat'l Ed. Acceptance, Inc. v. The Mars Corp.
  d/b/a Heavenly Ham, 2003 TCPA Rep. 1089 (2003)
  (order granting pl. MSJ.)
• Onsite Computer Consulting Svcs., Inc. v. Jansen,
  2006 TCPA Rep. 1518 (2006) (order granting ptf.
  MSJ)
• Onsite Computer Consulting Svcs., Inc., v. Dartek
  Compter Supply Corp., 2006 TCPA Rep. 1452 (2006)
  (order denying MTD)
• Platke Berkowitz, LLP v. IhireInc.Com, Inc.,
  2005 TCPA Rep. 1090 (2005) (Ptf. MSJ granted)
• Psych. Assoc., v. Whittemore Corp., 2005 TCPA
  Rep. 1371 (2005) (order denying Def. MTD.)
• Psychological Associates, Inc. v. Advanced
  Tracking Tech., Inc., d/b/a Glaco, 2004 TCPA Rep.
  1316 (2004) (order denying def. MTD)
• R.F. Schraut Heating Cooling, Inc. v. Maio
  Success Sys., Inc., 2001 TCPA Rep. 1038 (2001)
  (order denying Def. Mtn. to dismiss)
• Reynolds v. Diamond Foods Poultry, Inc., 2002
  TCPA Rep. 1048 (2002) (appeal reversing trial
  court dismissal based on opt-in argument)
• Reynolds v. Diamond Foods Poultry, Inc., 2002
  TCPA Rep. 1175 (2002) (affirming court of appeals
  holding that no "opt-in" is needed)
• Rhone v. Olympic Comm., Inc., 2002 TCPA Rep. 1060
  (2002) (order granting Pl. MSJ)
• Schraut v. Rocky Mtn. Reclamation, 2001 TCPA Rep.
  1182 (2001) (Order denying def. MTD)
• Schumacher Fin. Svcs., Inc. v. Allianz Life Ins.
  Co. of North Am., 2002 TCPA Rep. 1100 (2002)
  (form order denying def. MSJ.)

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• Schumacher Fin. Svcs., Inc. v. Metropark Comm.,
  2003 TCPA Rep. 1093 (2003) (order granting pl.
  MSJ)
• Schumacher Fin. Svcs., Inc. v. Nat'l Fed'n of
  Ind. Bus., 2003 TCPA Rep. 1088 (2003) (order
  granting pl. MSJ)
• Schumacher Fin. Svcs., Inc. v. Sorkins'
  Directories, Inc., 2004 TCPA Rep. 1264 (2004)
  (order denying def. MSJ and granting ptf's. MSJ.)
• Schumacher Fin. Svcs., Inc. v. Steckleberg, 2003
  TCPA Rep. 1236 (2003) (order denying def. MTD)
• State ex rel Nixon v. E. Dish Direct, 2006 TCPA
  Rep. 1539 (2006) (TRO granted)
• State ex rel Nixon v. Progressive Bus. Pubs.,
  Inc., 2007 TCPA Rep. 1538 (2007) (MTD granted)
• State ex rel. Coffman Group v. Sweeney, 2005 TCPA
  Rep. 1391 (2005) (Preliminary order made
  permanent in part and dissolved in part.)
• State of Missouri ex rel JDT Enterprises, d/b/a
  Travel To Go, 2004 TCPA Rep. 1310 (2004) (writ of
  prohibition denied)
• State of Missouri v. Am. Blast Fax, Inc., 2003
  TCPA Rep. 1188 (2003) (order upholding
  constitutinality and reversing trial court)
• State of Missouri v. Am. Blast Fax, Inc., 2002
  TCPA Rep. 1196 (2002) (order gtanting def. MTD on
  first amendment grounds)
• State of Missouri v. Am. Blast Fax, Inc., 2001
  TCPA Rep. 1228 (2001) (order denying discovery)

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What went wrong?
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Purported purpose of enacting TCPA

• Congress found
• (5) Unrestricted telemarketing can be an
  intrusive invasion of privacy
• (7) Over half the States now have statutes
  restricting various uses of the telephone for
  marketing, but telemarketers can evade their
  prohibitions through interstate operations
  therefore, Federal law is needed to control
  residential telemarketing practices.
• (9) Individuals' privacy rights, public safety
  interests, and commercial freedoms of speech and
  trade must be balanced in a way that protects the
  privacy of individuals and permits legitimate
  telemarketing practices.
• (10) Evidence compiled by the Congress indicates
  that residential telephone subscribers consider
  automated or prerecorded telephone calls,
  regardless of the content or the initiator of the
  message, to be a nuisance and an invasion of
  privacy.
• (12) Banning such automated or prerecorded
  telephone calls to the home, except when the
  receiving party consents to receiving the call or
  when such calls are necessary in an emergency
  situation affecting the health and safety of the
  consumer, is the only effective means of
  protecting telephone consumers from this nuisance
  and privacy invasion.14
• Telephone Consumer Protection Act of 1991, Pub.
  L. No. 102-243, 2, 105 Stat. 2394.

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In 1999, FCC brings its first enforcement action
under TCPA

• FCC levies 5.38 million fine against Fax.com
• TCPA prohibits
• Prohibits sending unsolicited advertising via
  fax.
• Statute provides for 500 per violation and up to
  1500 in treble damages, if conduct willful.

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Fax Fiasco as a Framework for the Future

• An inexpensive and exciting new marketing
  practice becomes abused or overused.
• Public outcry about invasion of privacy resulting
  in government intervention and fines.
• Legitimate companies caught in the crossfire
  either by relationship with perpetrator or their
  own lack of understanding of the laws.

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Fax Fiasco as a Framework for the Future

• Plaintiffs lawyers employ class actions to
  exponentially increase potential damages.
• Defense costs to defend individual claims cost
  prohibitive.

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Beyond Faxes Emerging Legal Issues
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• Compiling and storing customer/client information
• Adware
• Text message marketing

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• FTC estimated that identity theft costs Americans
  50 billion per year and opined that lack of
  controls on consumer privacy data contributed to
  increase in identity thefts.
• DSW Shoe Warehouse 1.4 million names and credit
  card numbers stolen. Thus far, paid up to 10
  million in reimbursment to consumers who incurred
  expenses (closed accounts, new checks etc..)

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• Choicepoint 163,000 consumers credit histories
  and personal information provided to identity
  thefts. Fined 10 million by FTC.
• TJMax Hackers stole consumer credit card and
  debit card information (January 2007)

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Consumers reaction

• A national survey conducted in June 2004 by
  Privacy and American Business found
• 87 of consumers had asked a company to remove
  their name and address from marketing lists, an
  increase of 29 since 1999.
• 81 had asked a company not to sell or give their
  name and address to another company, up 28
  percent from 1999.
• 65 of online users, more than 94 million people,
  reported that they decided not to register at a
  website because they deemed the privacy policy
  too complicated or unclear

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Adware

• Defined Software that facilitates pop up ads,
  re-direction of search requests, and more.
• Example Mr. Smith downloads free software and
  unknowingly downloaded the adware, which
  thereafter monitors Mr. Smiths online activities
  and uses this information to direct certain ads
  to him while he surfs the web.
• Problem Lack of disclosure and difficulty of
  removing

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FTC v. Direct Revenue LLC

• In March of 2007, FTC collected 1.5 million fine
  from Direct Revenue LLC, a major online ad
  company, for acting deceptively by failing to
  disclose to consumers that downloading the free
  software would result in installation of adware
  and cause pop up ads.
• Also, the FTC found that Direct Revenue acted
  unfairly by failing to provide consumers a
  reasonable and effective means to identify,
  locate and remove adware.

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So well just let the adware company hang out
to dry on this one!
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Think again..

• In conjunction with the FTC investigation of
  Direct Revenue, the New York Attorney General
  settled its cases against the companies who
  contracted with Direct Revenue.
• Priceline.com and Travelocity.com agreed to pay
  fines between 30,000 to 35,000 and change their
  advertising policies.
• None of these companies knew, or even were
  alleged to have known, about Direct Revenues
  deceptive practices.

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• Companies will now be held responsible when
  their ads end up on consumers computers without
  full notice and consent.and cannot insulate
  themselves from liability by turning a blind eye
  to how their advertisements are delivered by
  placing their ads through intermediaries.
• New York Attorney General, Andrew Cuomo

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Texting as a marketing tool

• According to a recent article in the Journal of
  Advertising Research, as a direct marketing tool,
  texting could surpass internet-based advertising
  before the end of 2006.
• Randolph J. Trappey Iii and Arch G. Woodside,
  Journal of Advertising Research, Vol. 45, No. 4,
  Dec 2005, pp.382-401

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Texting and the law

• CAN-SPAM Act forbids sending unsolicited
  commercial emails to mobile devices without
  express prior authorization of the recipient
• Do-Not-Call Implementation Act - prohibits
  interstate telemarketing call to wireline and
  wireless numbers on the National Do-Not-Call
  Registry (with certain exemptions)
• FTCs Telemarketing Sales Rule which imposes
  regulations on telemarketing
• Various State statutes regulating marketing and
  promotions

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From plaintiffs law firm site

• Verdicts
• Claim was asserted under the Telephone Consumer
  Protection Act that prohibits sending unsolicited
  fax advertisements.  Certified Class of claimants
  consisted of 1,321 businesses and individuals who
  received unwanted fax advertisements over a six
  (6) week period.  Jury trial resulted in 11.9
  Million Judgment.
• Updates March 2006
• Sending text messages may constitute violations
  of the Telephone Consumer Protection Act.  The
  firm is now looking at filing cases involving the
  improper transmission of text messages to
  cellular telephones in violation of the Telephone
  Consumer Protection Act.

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• So what do you do?
• Stop advertising?
• Stop direct marketing?
• Stop using new technology?

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Tips and Tools to prevent future loss by avoiding
legal quagmires

• Implement policies and procedures to comply with
  the law and that are consumer/customer friendly.
• Employ less risky marketing tools with less
  government regulatory oversight.
• Transfer risk
• Respond to claims in the correct way.

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If you collect data on consumers, have a privacy
policy

• Privacy policies informs customers what
  information is collected and how it will be used.

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Impact of a well-crafted privacy policy?

• A recent national study found that consumers
  gauge a companys privacy trust-worthiness by
  three criteria
• Most importantly, companys overall service and
  product quality
• Companys limits on collection of its consumers
  personal information.
• The use of advertisements and solicitation that
  respect consumer privacy.
• Ponemon Institute Study, 2004.

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So what does a higher privacy trust rating mean
for my bottom line?

• The study also found that organizations that
  achieve higher privacy trust ratings experience
  tangible positive outcomes, such as
• Higher consumer data accuracy
• Higher customer participation in online
  activities
• Higher product or brand loyalty
• Ponemon Institute Study, 2004.

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Privacy policy contents

• Recognizable (i.e. clearly labeled that it is the
  privacy statement.)
• Readily accessible
• Clear and understandable
• Describe how you collect personal information and
  what type
• Describe how you use the personal information and
  to whom you share it with
• Give customers a choice on how their personal
  information is used or disclosed
• Provide general descriptions on your security
  measures
• Identify person whom consumers can contact to
  complain
• Source California Office of Privacy Protection

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Loss control measures in online advertising

• If using adware, be sure your policies (or those
  of the adware company you are contracting with)
  clearly include disclosures to the consumers upon
  downloading of adware.
• Remove onerous obstacles to deleting adware.
• Bind advertising partners by contract to
  consumer-friendly practices.
• Regularly monitor advertising partners practices
  and policies.
• Contract with well-established companies to
  provide online ad services.

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Utilize less risky marketing techniques

• Blogging
• E-mail

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Blogging

• One commentator described blogs as rocket-fuel
  publicity. Mentions on popular blogs can result
  in an intense amount of activity over a short
  period of time.
• Your new best friend
• Section 230 of the Communications Decency Act
  of 1996.

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Section 230 of the Communications Decency Act of
1996

• Provides immunity from liability for providers
  and users of an "interactive computer service"
  who publish information provided by others
• No provider or user of an interactive computer
  service shall be treated as the publisher or
  speaker of any information provided by another
  information content provider.

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E-mail marketing

• CAN-SPAM permits e-mail marketers to send
  unsolicited commercial e-mail as long as it
  contains all of
• an opt-out mechanism
• a valid subject line and header (routing)
  information
• the legitimate physical address of the mailer
  and
• a label if the content is adult.
• Private individuals cannot sue under CAN-SPAM
  act, only state attorney generals and ISPs.
• CAN-SPAM preempts (supersedes) existing state
  anti-spam laws.

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Transfer Your Risk

• Contractual Management
• Indemnity provisions and Hold Harmless agreements
• Hire a lawyer

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Agency v. Advertiser Who assumes the risk?

• Agency
• Must receive sustantiation for each claim.
• Not held liable, unless it knew or had reason to
  know that the substantiation possessed by
  advertiser was invalid.
• Must obtain rights to the material (music, logos
  etc..) it includes in the advertising.

• Advertiser
• Advertiser ALWAYS held responsible for claims
  made in advertising.
• Should contractually obligate the agency to
  acquire all rights in materials used in any
  advertising produced.

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Who are in bed with?

• Are you outsourcing your data management.
• What do the agreements say?
• Who indemnifies who?
• Are they insured?
• Is their address a P.O. Box in the Ukraine?

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Invest in insurance and loss control services

• Media liability insurance
• Cyber liability be sure current policy covers
  cyber exposure.
• Claims reporting report it all promptly

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Invest in insurance and loss control services

• M/PI loss control services provides
• On-site assessments.
• Educational and training seminars.
• Loss control strategies and procedures.

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People Dont Sue Nice Doctors
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The 3.3 minute difference

• Weve had people come in saying they want to sue
  some specialist, and well say, We dont think
  that doctor was negligent. We think its your
  primary care doctor who was at fault. And the
  client will say, I dont care what she did. I
  love her, and Im not suing her.
• Source Blink by Malcolm Gladwell
• 18.3 minutes Never sued
• 15 minutes Sued more than two times

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Responding to a claim

• Keep it a claim, take complaints seriously and
  correct them if necessary.
• Be creative in resolution. (Free advertising,
  free product?)
• Dont admit anything until you consult an
  attorney
• Keep track of all communication and correspondence

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THANK YOU FOR YOUR TIME

• For more information about Media/Professional
  Insurances Loss Control Services, please
  contact
• Scott A. Swift
• Loss Control Counsel
• Media/Professional Insurance, Inc.
• 2300 Main Street
• Kansas City, Missouri 64108