8311005 Informal Interpretation

(redacted)

November 8, 1983

Pre-Merger Notification Office
Bureau of Competition
Federal Trade Commission
Room 301
Washington, D.C. 20580

Attention: Ms. Sandra Vidas

Re:Confirmation of Exempt From
Hart-Scott-Rodino Reporting
Requirements

Dear Ms. Vidas:

This will confirm our telephone conversation of November 7, 1983 in which you advised that the transaction between (redacted) and (redacted) described in my letter to you of October 28, 1983, is exempt from the reporting requirements of the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (15 U.S.C. 18a). This transaction is exempt since it involves an acquisition by (redacted) of an undivided interest (realty) in the ordinary course of business and in a certain joint venture interest which, taken together, do not represent all or substantially all of (redacted) interest in the joint venture described in my October 28, 1983 letter. In addition, possible future transactions of oil and gas leases or related interests from (redacted) and then from (redacted) are not currently reportable since they are speculative at this time.

Please contact me if this letter is not an accurate summary of our conversation. Also, I would appreciate it if you could have the enclosed photocopy of this letter date-stamped by your office and returned to me in the enclosed stamped, self-addressed envelop.

Thank you for your assistance in this matter.

Sincerely yours,

(Redacted)

Enclosure

(redacted)