0709006 Informal Interpretation

September 11, 2007

B.Michael Verne

Federal Trade Commission

Premerger Notification Office

601 Pennsylvania Avenue, NW

Room 303

Washington, D.C. 20580

Re: Item 4(c)Question Dear Mike,

This is confirming our telephoneconversation regarding how to handle classified 4(c) documents. Our client has documents responsive to Item 4(c) thathave classification levels above Top Secret (Special Compartmentalized Access).You confirmed that we could withhold thesedocuments from our HSR filing because the FTC staff does not have the typeof clearance necessary to review these documents.