0807008 Informal Interpretation

From: (REDACTED)

Sent: Monday, July 14, 2008 5:15 PM

To: Verne, B. Michael

Subject: foreign government entity

Mike

Could you please advise on how this affects an acquisition by a joint venture.

The joint venture is owned 85/15%. The 85% belongs to a foreign government entity that seems to qualify for an exemption under 801.1 (a)(2), the 15% to a private company.

I understand that the filing requirement now reverts to the joint venture (Int. 34), but I just want to confirm that the private company that owns the 15% has no filing obligations of its own.

Thank you.