So how would you respond to 47 U.S.C. 276 (c)(d)? [1]
(c) STATE PREEMPTION To the extent that any State requirements are inconsistent with the Commission's regulations, the Commission's regulations on such matters shall preempt such State requirements.
(d) DEFINITION As used in this section, the term ''payphone service'' means the provision of public or semi-public pay telephones, the provision of inmate telephone service in correctional institutions, and any ancillary services.
This explicitly states that since inception, the FCC has been directed by congress to have jurisdiction over __inmate telephone service__, and __any ancillary services__.
How can you have anything __more__ direct than this language?