1203004 Informal Interpretation

From:

(Redacted)

Sent:

Wednesday, March 14, 2012 3:20 PM

To:

Verne, B. Michael

Subject:

PRIOR REQUEST

MIKE, the spinoff ofCompany B in my prior email was not pro rata; I do not think this matters asthe spun off divisions were part of Company A at the time of the originalfiling and as noted, the same antitrust review occurred; opinion 242 (example3) does not require pro rata spin off, only that the spun off Company was, ineffect, part of the original filing acquiring person, thanks Victor

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