8912007 Informal Interpretation

(redacted)

Premerger Notification Office
Bureau of Competition
Federal Trade Commission
600 Pennsylvania Avenue, NW, Room 303
Washington, D.C. 20580

Re:

Dear Patrick:

I am writing this letter to confirm our telephone conversation of this morning in which you furnished me with the following responses to my letter to you dated December 12, 1989:

1.The only aspects of the transactions described in my December 12 letter which could be reportable under the Hart-Scott-Rodino Act are the acquisitions of the adjoining properties for expansion and development.

2.Each of those acquisitions will stand on its own and if any single acquisition exceeds $15 million and the other Hart-Scott-Rodino tests are satisfied, then that portion of the transaction will be reportable.

3.For the purpose of this letter, any acquired properties which are under common ownership at the time of acquisition shall be aggregated and treated by the Department as a single acquisition.

4.I would appreciate your retaining a copy of this letter in your departmental files.

Very truly yours,

cc: (redacted)