9012012 Informal Interpretation

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

Re:Premerger Notification Compliance under the Hart-Scott-Rodino Act

Dear Ms. Bruno:

Thank you for your assistance by telephone today. I appreciated the opportunity to clarify and confirm our interpretation of the rules implementing the Hart-Scott-Rodino Act as a follow-up to my November 30, 1990, letter to Mr. Patrick Sharpe. This letter is to confirm my understanding based on our discussion by telephone today.

With respect to acquisitions of certain kinds of real property, if a structure is deemed to be an office building at the time of acquisition, and the value of non-office space in that structure is $15 million or less, the acquisition will be exempt from the requirements of the Hart-Scott-Rodino Act.

If my understanding is incorrect, please notify me as soon as possible. My phone number is stated above.

Very truly yours

cc: (redacted)