In 2010 and 2011, Mr. Davis represented two entities opposing specific federal regulation targeting for-profit colleges: The Coalition for Educational Success, a group composed of several companies that own and operate for-profit higher education colleges in the U.S., and the National Black Chamber of Commerce. These clients did not overlap, but both dealt with the same interests. Mr. Davis’s representation consisted of assembling relevant facts about for-profit colleges and then both distributing them to and lobbying relevant political actors to make all of the information on the subject known. The facts revealed major inaccuracies in a report by the Government Accountability Office and flaws in the logic of the “gainful employment” rule being considered by the U.S. Department of Education that would have unintended consequences that would adversely affect minorities and low-income families. Consistent with all of his representation, Mr. Davis’s work focused on making all the facts known. In this capacity, he wrote several op-eds on the subject, in which he disclosed his position with the for-profit college interests, and co-wrote a white paper with the National Black Chamber of Commerce detailing the flaws of the “gainful employment” rule.