8812008 Informal Interpretation

December 28, 1988

VIA TELECOPY

(redacted)

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

Attention: Mr. Patrick Sharpe

Gentlemen:

I am writing on behalf of a client of our firm to confirm the informal policy of the Federal Trade Commission Staff (the Staff) regarding an interpretation of the Hart-Scott-Rodino Act (the Act) that was conveyed to me in a telephone conversation with Mr. Patrick Sharpe today. With respect to Rule 803.2(c)(1), which provides that the information called for by items 5,7, 8 and 9 and the appendix to the Notification and report form shall be supplied only with respect to operations conducted within the United States, I understand that sales by a foreign entity of goods manufactured abroad directly to United States purchasers without the assistance of any United States purchasers without the assistance of any United States-bases sales establishments do not arise with respect to operations conducted within the United States.

Please call me (collect) at the above telephone number if the foregoing is in accordance with the present policies of the Staff. I further request that you maintain a copy of this letter in your files for future reference. Your assistance in this matter has been very much appreciated.

Sincerely,

cc: (redacted)