0002007 Informal Interpretation

[redacted]

February 15, 2000

Via Facsimile

Ms. Nancy Ovuka

Bureau of Competition

Federal Trade Commission

6th & Pennsylvania Avenue, N.W.

Room 303

Washington, D.C. 20580

Dear Ms. Ovuka:

This will memorialize our conversation on February 15, 2000 in which you confirmed that 16 C.F.R. 802.5 would be applicable in the following transaction:

Company A intends to sublease from Company B. Company A is not a telecommunications carrier, but rather is in the business of owning, leasing and managing towers on which third-party telecommunication carriers can place their cellular and other telecommunications equipment. Company A will not use the towers to run its own broadcasting or telecommunications business.

I trust that the forgoing accurately reflects the views of the Premerger Notification Office. Please feel free to call me if I have misunderstood your advice. Thank you.

Sincerely,

[redacted]

Enc.

[redacted]

cc: [redacted]