8705001 Informal Interpretation

(redacted)

May 1, 1987

Patrick Sharpe
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
6th & Pennsylvania Avenue, NW
Room 303
Washington, D.C. 20580

Re: Applicability of Hart-Scott-Rodino Premerger Notification
Requirements to Asset Purchase Agreement Between (redacted)

Dear Mr. Sharpe:

By this letter I am confirming our conversation of April 30, 1987 regarding the applicability to the above-referenced transaction (the Transaction) of the premerger notification requirements set forth in 15 U.S.C. 18A (the Reporting Requirement).

I represented to you that the acquiring party in the Transaction, (redacted) is a corporation which was formed recently for the purpose of acquiring the radio broadcasting assets which are the subject of the Transaction from the acquired party, (redacted) assets as of the date hereof consist solely of funds contributed to (redacted) as an initial capitalization and total less than $10 Million. (Redacted) will borrow additional funds to finance its acquisition of the Assets. I have relied on the representation of (redacted) counsel as the basis for these factual matters.

Based on these factual representations, you have informed me that the Reporting Requirements are not applicable to the Transaction. Accordingly, (redacted) has not filed a Premerger Notification And Report Form For Certain Mergers And Acquisitions pursuant to 16 C.F.R. 801 et seq.

[response 1]

Please call me if this letter does not accurately characterize our conversation. Thank you for your cooperation in this matter.

Very truly yours,

(Redacted)

(redacted)

cc:(redacted)