0212015 Informal Interpretation

From: (redacted)

Sent: Monday, December 20, 2002 4:19 PM
To: Michael Verne
Subject: HSR question

Mike,

I have a quick question:

Is the following transaction subject to HSR:

We acquire $8 million of voting securities and $52 million of non-voting preferred stock (convetible into non-voting common). Staff comment not reportable.

Who pays the filing fee (regardless of the type or form of transaction)? Staff comment acquiring person

Thanks for your help.