9508007 Informal Interpretation

August 18, 1995

VIA TELECOPIER/REGULAR U.S.MAIL

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

Re: (redacted)

Dear Patrick:

The purpose of this letter is to request an interpretation from the Federal Trade Commission (FTC) (premerger office not the commission) of the requirements under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 and the related FTC rules (the Act) as applied to the propose (redacted) transaction among (redacted) and their respective affiliates. More specifically, we would like to know whether one or more of the parties to the proposed transaction are required to file a completed Notification and Report Form under the Act prior to consummation of the proposed transaction. Pursuant to our telephone conference on August 9, 1995, a detailed description of the proposed transaction is enclosed.

For your information (redacted) is the parent company of (redacted) which in turn is the indirect parent company of (redacted) Company. (redacted) the parent company of (redacted) Company, which in turn is the parent company of The (redacted) is not affiliated with any of the other parties to the (redacted) transactions.

The parties to the proposed transaction would like to proceed as promptly as possible and, therefore, your immediate attention to this matter would be most appreciated.

If you have any questions or would like to discuss the request being made, please contact me collect at (redacted) or you may call (redacted) legal counsel for (redacted). Thank you in advance for your kind assistance with respect to this matter.

(redacted)

cc: (redacted)