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  "documentTitle": "Clear Secure, Inc. (YOU)",
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  "authorName": "Spruce Point Capital Management",
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  "presentationDate": "2025-04-30 00:00:00",
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  "notes": "Uses a quote from a former senior TSA employee to highlight the regulatory barrier.",
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      "text": "Spruce Point believes it will be critical for CLEAR's business to have the TSA lift the legal definition of the traveler document checker (i.e. TSA officer).",
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      "text": "According to a former senior TSA employee, CLEAR was able to work with the TSA to implement an electronic “confer and concur” program. This allowed CLEAR’s biometric pods to send the CLEAR members’ data to the TSA’s backend secure flight data for verification. This allowed CLEAR members to avoid showing their ID or boarding pass again to the TSA officer. Spruce Point believes it will be critical for CLEAR’s business to have the TSA lift the legal definition of the traveler document checker (i.e. TSA officer). This would potentially allow CLEAR members to completely bypass the TSA officer and move directly to the carry-on baggage scanner.",
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      "text": "“So CLEAR does not have access to secure flight. So the TSA officers responsible for directing that passenger to the appropriate level of screening. And in the old days it was manual conferring and concur. The officer had to look at the boarding pass and make sure the passenger was pre-check or standard. Now that's performed electronically. So it really is, it's threefold, and maybe I didn't explain it quite thoroughly enough before, number one, the conferring concur process made sure that the that passenger had a valid boarding pass for a flight that day. CLEAR doesn't check that right. Number two, and make sure that the officer can direct that passenger the appropriate level of screening, which again, CLEAR cannot do. And then number three, on a random basis, as of a year ago, and now all passengers in certain locations, they do this electronic confer and concur where TSA actually electronically validates that yes, that's the person they had a flight that day and where they need to go for screening.”",
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      "kind": "quote",
      "text": "“Okay, so CLEAR does not have access to secure flight, and they've always wanted it. The former administrator, Pekoske drew a pretty hard line that CLEAR as a private for-profit company could not get access to secure flight data. And his position was that identity verification step, right? The whole identity management thing that I just described, that was an inherently governmental function. He characterized that as really the first encounter that a passenger has with security, and he was reluctant to cede that responsibility to a private company.”",
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      "text": "“And the other thing, and again, this is a political deal. The former administrator viewed the travel document checker (TDC) position as inherently governmental, and there was a legal rendering that existed that that position was inherently governmental. And to allow CLEAR to solely do that function would require TSA to rethink that decision. So the whole inherently governmental thing, right, it led to the random validation of identity at the TDC, then the electronic confer and concur, and it's where we are today.”",
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      "text": "So CLEAR does not have access to secure flight. So the TSA officers responsible for directing that passenger to the appropriate level of screening... CLEAR cannot do. — Former Senior TSA Employee",
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      "text": "Source: Spruce Point research interview",
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      "text": "It Appears A Legal Definition Is Hindering CLEAR’s Business",
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      "text": "Spruce Point Interview With A Former Senior TSA Employee",
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