9107001 Informal Interpretation

July 1, 1991

VIA TELECOPIER

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

Re:

Dear Mr. Smith:

This letter is to confirm our telephone conversation today in which you stated that in accordance with Paragraph 169 of the ABAs Premerger Notification Practice Manual, written notification to all the shareholders of a closely held corporation will satisfy the public announcement requirement under Section 803.5(a)(2) of the Premerger Notification Rules.

If my understanding of the public announcement requirement is incorrect in any way, please contact me at (redacted).

Sincerely,

(Redacted)

cc: (redacted)