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Metrc

4151 S Pipkin Rd., Lakeland, Florida, United States, 33811-1425

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This is a formal complaint to be filed against the cannabis compliance technology tracking supplier Metrc/Franwell Inc, with corporate offices shown at 2525 Drane Field Rd. Suite 8, Lakeland, FL 33811. This complaint is for incompetence and discrimination in business practices regarding the implementation of the Metrc programming / reporting API that Franwell has provided for several States. And that such incompetence and discrimination has likewise adversely affected our ability to do business in any State.

Our HUB Zone-based small company was approved as a 3rd-party integrator on October 16th, 2018. As with each integrator, we are required to pass a series of tests with Metrc that prove a valid interchange of data between the integrator and Metrc reporting API. Only after such testing is completed can we be added to each State's Approved Integrators list and our product sold to the cannabis industry in each State.

Our software development testing with the Metrc API began that same day, as did the problems we encountered trying to complete the process. Documentation can be provided on request showing that nearly 100 emails have been exchanged, code samples have been provided, screen shots of values sent to their support, all documenting their technical issues in detail and showing how their testing process is NOT fair to newer integrators, and yet after more than two months Metrc has still failed to make it possible for us to complete their testing.

This failure violates Metrc/Franwell's agreement with each State to provide equal access to all 3rd-party integrators. Furthermore, it blocks our company's ability to do business. We will show that Franwell is liable due to Metrc's failure to be in compliance with all integrators equally in four separate ways: Lack of technical documentation, incorrect support instructions, failure to resolve their own technical issues and failure to provide dedicated support. Detailed complaints have been filed with related State regulatory agencies.

Desired Outcome

Contact by the Business Provide the necessary dedicated technical support to allow for full IMMEDIATE completion of the API testing and State approval processes. Email documentation related this complaint can show that from the beginning, the only demand from our side has been to receive ONE HOUR of real-time phone support with a knowledgeable technical person who can actually resolve the issues. (or whatever time is needed to complete a total of about 12 tests)

Metrc Response • Feb 07, 2019

February 6, 2019
***
Consumer Affairs Represerpative
Revdex.com `
1600 South Grant Street l
Long wood, FL 32750

Re Case # ***: ***
Your letter ofJanuary 23. 2019
Dear Ms.:
This is in response to your referenced case number and letter. Thank you for granting us an
extension until February 6, 20l9 to respond to you, as you conrmed in the telephone conference with
our legal counsel, Williaml P, on February l. 2019. As Mr. P explained on the telephone. the
relationships of the various parties and the events involved are somewhat complicated. I have tried to be
as clear as l can in my explanation of the fundamental facts below. My use of certain defined terms is
intended both to make the details presented easier to understand and to conform to the terminology that is
actually used in this business.
1. *** and his company, *** ("*** "). are located in Keaau.
Hawaii at the address reected in the attachment to your letter. *** was not mentioned
in your letter. although Mr. made other complaints in the name of *** in several
other states. We believe that he markets and provides all his company"s services from Hawaii.
2. Mr. had informed us that he and his company offer a form of enterprise software to
persons who have been licensed by government agencies in states throughout the United States to
grow. process, and dispense legal cannabis ("Licensees"). There are numerous other computer
soware vendors Who have been doing this very thing for many years. We refer to such
enterprise software Ivendors as "Intagmtors" because they:
(a) develop software that, among other things. selects the applicable data required by the
*** System from the enterprise data put into the enterprise software program by the
Licensee, and
(b) then trarnsmits that applicable data to the regulating state government agency through
the *** System either (i) automatically by what is called an "application programming
interface" L- abbreviated as "API"; or (ii) as a manual data entry. which is both tedious
and error prone.
3. lntegrators obviously want to qualify for and use the ***, rather than manually re-enter
data in the *** $ystem from the data that has been enterred into the lntegrators" enterprise
software programsiby their Licensee customers. We certainly would like to see that done
efciently; and we have provided substantial time and effort by our employees to the lntegrators.
without charge, to try to help the lntegrators qualify to properly perform their rasks. The more
effectively and efcliently we can do that, the more economica! it is for us, since we do not charge
for that service but ¡must pay our staff to provide it.
4151 South Pipkin Road Lakeland, FI 33811-1425 863 583 0228
www.metrc.com

***
Consumer Affairs Representative
Revdex.com
February 6, 2019
Page 2
4.
5.
6.
7.
8.
4.The governments which have legal ¡zed cannabis and have engaged us to provide our ***
System to their Licensees (in order to report to such government bodies) have generally agreed to
allow us to provide a passcode (called a "Key") to the lntegrators who demonstrate that they are
qualified to correctly perform the data transmission function on behalf ofa Licensee. When that
competcncy is demonstrated to us by an lntegrator. we provide the lntegrator with a Key to our
***.
5.Mr. (actíng on behalfofhis company ***) has been substantially frustrated by
not being able to påss, on multiple occasions, the basic test requirements we have established to
determine competeilicy in using our ***.
6.We have undertaken an intemal investigation of the written criticisms Mr. has made of
our technical documentation, support instructions, resolution of technical issues, and dedicated
support. He has made those eomplaints to state regulatory agencies. as well as to the Revdex.com. ll have been infomted that our call center staff and managerial staff have spent
far more time trying to help Mr. qualify and properly perform the lntegrator functions to
qualify for access to the *** Key (in the states where he has sought to so qualiy) than
with any other of thie more than 200 such lntegrators with whom we have worked.
7.lt is important to understand that nether Mr., nor ***, are our customers. We do
not sell anything tolMr, ***, or ***, or any other lntegrator. The technical assistance
we provide to themlis all complimentary.
8.We regret that Mrl *** has not been able to understand and follow our oral and written
instructions. We have never refused to try to assist him in this regard. and we will continue to
provde him with the same guidance and information we have provided and continue to provide to
all other lntegratorsl.
I hope this has been helpful in providing an understanding of what we have been trying to
accomplish in dealing withlMr. and his company and in fullling our contractual responsibìlities
to the various government agencies with whom we have contracted to provide our technology.

Sincerely

Emest J. F, .lr.
Vice President and Chief Financial Ofcer
for
Jeffrey L. W
Chief Executive Officer
4151 South Plpkin Road Lakeland, Fl 33811-1425
www.metrc,com
863 583 0228

Customer Response • Feb 07, 2019

(The consumer indicated he/she DID NOT accept the response from the business.)
What a load of legalizmo nonsense. It's NOT complex as they would have you believe, in fact it's very simple. We poor sad people who according to them can't follow instructions have been certified in other States in UNDER ONE WEEK when provided with VALID test data. We can provide documentation that proves it, just ask for it! Don't be fooled by the fog they spew trying to make anything complex. They run a public API and need to provide VALID test data for it for integrators who want to send dat to that API. Duh, like that's "complex" to grasp. They can prove NOT ONE WORD of what they say, we can prove ALL of what we say. It is METRC / FRANWELL ALONE that bears responsibility for BLOCKING OUR BUSINESS FOR FOUR MONTHS IN VARIOUS STATES because they FAIL TO PROVIDE WORKING TEST DATA. They now have a blossoming national reputation for very poor support, easily verified and well-deserved. To this day, they have STILL failed to provide working test data for all States! Including and most especially CALIFORNIA.

UNFAIR BUSINESS PRACTICES, FRANWELL. And they CONTINUE. Late integrators ARE at a disadvantage. We can and will PROVE that is true. Can you PROVE otherwise? Put that PROOF in our next reply to this complaint or else you de facto admit the truth of your guilt. The clock of legal and financial liability around those practices is still running on you, don't doubt it.

Customer Response • Feb 26, 2019

(The consumer indicated he/she DID NOT accept the response from the business.)
*** has yes indeed AT LAST complied in sending valid test data for CA as they finally complied in the previous States, just as they say. The dates they provide are a confession: they were originally asked for support and valid test data in OCTOBER 2018. It took them FOUR MONTHS to provide valid test data for us as a later integrator. They can also confirm that once they DID send valid data, we finished the process in ONE BUSINESS DAY. (obviously as clear evidence of our lack of good faith effort) ;-) (what a load of crap) There was NEVER technical debt on our end at ANY time.

Franwell is legally and financially liable for turning a one day process into a four month process, during which time they alternatively refused to provide support and provided incompetent support, all the while holding the livelihood of our business in their hands. And they refused any additional support even when that was clearly pointed out. It's unfair and as such it's blatantly obviously illegal. And they make it clear it is their PRACTICE. (Aand the more complaining they do in print about how much effort they put into supporting us, how above and beyond the ordinary it was, the clearer they make it how much their support typically SUCKS . . . all we EVER asked for is VALID TEST DATA for a REQUIRED API test! Clown show.)

***y should NOT be the cannabis compliance database in ANY State. To state regulators and to integrators: if you haven't learned the lesson yet from your own experiences: BEWARE.

Metrc Response • Feb 26, 2019

metrc
February 25, 2019
***
Consumer Affairs Representative
Revdex.com
1600 South Grant Street
Longwood, FL 32750
Re: Case # ***: *** and your letter of February 12, 2019

Dear Ms.:

This is in response to your above referenced letter and case number pertaining to the complaints by *** of Hawaii. As with our Februaiy 6, 2019 letter in reply to your January 23, 2019 letter conceming Mr., *** LLC ("***") is replying for both Franwell, lnc. ("FranwelI") and *** itself, since all of Franwell`s business operations have been assigned to and assumed by *** as of
September 2018.
Notwithstanding the antagonistic attitutude Mr. has had (us reected in his response
dated 02/07/2019 to our letter of the previous day) regarding our efforts to help him qualify to use our
application programming interface ("API") in the software program he offers to licensees of various
states, we have continued our efforts to help him so qualify. Our efforts have been substantial. Having
him qualied (a/lc/a "validated") efciently and effectively in each state where he sought to access our
*** was certainly in our best interest, and we never ceased making efforts to help him. The
difculties and frustrations of Mr. in achieving validation have adversely affected us due to the
cost of our employee resources we devoted to him and other extra expenses that resulted from his actions.
Please note that prior to the 02/07/2019 response by Mr. to our February 6, 2019 letter,
we had trained and validated him in Alaska, Massachussetts. Montana, Nevada. and Oregon. where he has
had access to our API since January 17, 2019. Also prior to that 02/07/2019 response by Mr., we
likewise had trained and validated him in Colorado and Ohio, both effective February 1, 2019. Further,
since those seven validations, we have validated Mr. in Califomia, effective February 14. 2019.
ln addition to providing Mr. with our API in the above eight states, we are working with
him in his application to qualífy for our API in the District of Columbia, Maryland. and Michigan. We
are not aware of any legal obligation we have to do anything more than we have done in working with
him. 1 would hope that at some point Mr. will have some appreciation for the effons we have
made and the assistance we have given to him.
We believe that the optimal resolution of this matter will be achieved by our continued efforts to
help Mr. obtain Validation in the remaingjurisdictions and a diligent effort by him to satisfy each
validation requirement. We are commited to doing our part. We urge Mr. to do the same.
Sincerely,

Jeffrey L.W***
ChiefExecutive Ofcer
4151 South Pipkin Road Lakeland, FI 33811-1425 863 583 0228
wvwv.metrc.com

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Address: 4151 S Pipkin Rd., Lakeland, Florida, United States, 33811-1425

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