8606012 Informal Interpretation

(redacted)

June 19, 1986

Mr. Andrew Scanlon
Compliance Specialist
Premerger Notification Office
Bureau of Competition, Room 303
Federal Trade Commission
Washington, D.C. 20580

Dear Mr. Scanlon:

RE: Acquisition by (redacted) of (redacted)

Pursuant to our telephone conversation of yesterday afternoon, I enclose herewith a letter submitted by (redacted) describing the terms of an acquisition by (redacted) a wholly-owned subsidiary of (redacted).

As we discussed in our telephone conversation, we have concluded that a Hart-Scott-Rodino filing will not be required because (redacted) Inc. is a newly formed corporation which, following the acquisition, will have total assets of less than $10,000,000.

You may recall that I mentioned to you that the parties are hoping to close their transaction tomorrow. We would be grateful if you could review the enclosed submission and advise us immediately if you disagree with our analysis of the transaction or our conclusion that a Hart-Scott-Rodino filing will not be required.

My thanks to you for your assistance on such short notice.

Very truly yours,

(redacted)

(redacted)

Enclosure