2505010 Informal Interpretation

Seller and Buyer, both US companies, own assets used in the Service X business (the “Service X Assets”). Buyer operates Seller’s US Service X Assets pursuant to an Operating Agreement. Buyer is acquiring substantially all of Seller’s US Service X Assets. Seller’s UPE is a foreign issuer with global operations. Seller is controlled directly or indirectly for HSR purposes by multiple foreign entities unrelated to the transaction that are engaged in the Service X business in numerous locations outside of the US. Collection and production of all Plans and Reports prepared within the last year that analyze market shares, competition, competitors, or markets pertaining to the Service X business that were provided to the CEO or the Board of Directors of Seller or any entity it controls or is controlled by would require searching the files of numerous individuals not involved in the transaction and may likely result in the production of numerous documents (possibly hundreds) that provide no insight into competitive effects. Can you confirm whether Seller may limit the production of Plans and Reports to those Plans and Reports pertaining the Service X business in the US, or to those Plans and Reports provided only to the CEO or BOD of Seller?