0002013 Informal Interpretation

[redacted]

Fax Cover Sheet

To: Mr. Patrick Sharp

Fax: (202) 326-2624

From: [redacted]

Date: February 24, 2000 9:36 AM

Re: [redacted]

Pages: Cover Sheet

Operator: [redacted]

Operator Ext: [redacted]

Comments: Patrick: [redacted] will be filing an HSR Notification within the next week or so relevant to an acquisition of various newspaper assets located in[redacted] and [redacted] . The purchase price will be in the neighborhood of $100,100,000. A subsidiary of will purchase by assignment from $45,765,000 of the assets located in [redacted] and [redacted] will purchase the remaining properties and properties for $54,335,000.

[redacted] owns 50% of the voting stock of its subsidiary and qualifies as a "person" pursuant to 16 CFR 801.1. Accordingly, I am of the opinion that [redacted] can make one HSR filing. Please correct me if that's not your understanding.

My question is this: Do we need to provide the revenue figures for [redacted] only as the Ultimate Parent or do we need to include the subsidiary's revenue figures? [redacted] allows the dividends it receives from the subsidiary in its income statements and reports its equity investment on the balance sheet. does not separately report the subsidiary's revenue and expenses.

Your thoughts on the matter would be greatly appreciated. I can be reached at [redacted]. Thank you.