8906003 Informal Interpretation

(redacted)

VIA TELECOPY

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

Dear Mr. Cohen:

This letter is to seek formal advise on the question I put to you earlier today in our telephone conversation.

Specifically, I seek advice as to how your office views the location of ocean going containers, owned by a foreign corporation, and which, while under lease to shipping companies, may be transitorily in the United States in the process of being loaded, unloaded or transhipped overland. The question is relevant to an analysis of a possible transaction under Section 802.50 of the Pre-Merger Notification Rules.

Thank you for your assistance. I would appreciate a response by telecopy.

Sincerely,

cc: (redacted)