1204004 Informal Interpretation

From:

(redacted)

Sent:

Friday, April 13, 2012 12:53 PM

To:

Verne, B. Michael; Walsh, Kathryn

Subject:

Undersea Cable - US asset?

Hi-I am looking at a transaction where the target owns an undersea telecom cablewhich goes from Europe to NYC. I didn't see anything in the interpretationsthat sheds any light on (a) whether that could be considered a US asset or notand (b) if it is a US asset, how much of the cable would be deemed to be a USasset. It seems to me that the cable should not be a US asset because it is notactually in the US, being that it is in the ocean, but that the terminus inNYC, which is on land, would constitute a US asset. I would be grateful foryour thoughts.