8411004 Informal Interpretation

(redacted)

November 9, 1984

Mr. Andrew M. Scanlon
Compliance Specialist
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
Washington, DC 20580

Re:Premerger Notification

Dear Mr. Scanlon:

This is in response to your letter dated November 5, 1984 inquiring about the acquisition by (redacted) of the business of (redacted).

The proposed acquisition was announced on (redacted), these events were contemporaneously reported in The Wall Street Journal and other newspapers.

I believe it was in mid-August that my office received a call from a member of the Staff of the Premerger Notification Office (unfortunately, I do not have a record of the date of the call or the name of the Staff member who called) inquiring as to whether we were going to make a filing. We told the Staff member and we reconfirm here, our opinion that a filing was not required because this was a purchase of assets located outside the United States excluded from the requirement of filing in accordance with 802.50 of the Regulations: the sales into the United States attributable to the acquired foreign assets (redacted) were less than $25 million during (redacted) most recent fiscal year.

Very truly yours,

(redacted)