0207015 Informal Interpretation

From:(Redacted)

To:FTC.SERIUS(mverne ftc.gov")

Date:7/30/02 11:40AM

Subject:HSR filing Advice

Good Morning Mike I am hoping for confirmation that neither step in the following transaction is reportable:

Step 1 - Company A, Inc., which is owned 50% by Company B and 50% by Company B [sic], is being converted into an LLC.

Step 2 - Company D will purchase less than 50% of the membership interests of the LLC.

Please assume that the size of parties and size of transaction tests will be satisfied.

Thanks.

(Redacted)