0706004 Informal Interpretation

June 4, 2007

Michael B. Verne

Premerger Notification Office

Bureau of Competition

Federal Trade Commission

6th Street & Pennsylvania Avenue, NW

Washington, D.C.

Re:Exemption for Acquisition of Voting Securities of Registered Investment Company

DearMr. Verne:

(Redacted) (the Partnership) ownsapproximately 9% of the voting shares of (redacted) (the "Trust")which are currently valued at approximately $30 million. The Trust is aninvestment company registered with the U.S. Securities and Exchange Commissionunder the Investment Company Act of 1940. The Trust's SEC filings are availableat (redacted).

The Trust's assets consist entirelyof investment securities (none of which to our knowledge exceeds 15% of thevoting power of any issuer) which were acquired in the ordinary course ofbusiness and that it holds solely for the purpose of investment. Thus, theTrust's acquisitions of voting securities appear to be exempt from therequirements of the Hart-Scott-Rodino Act by virtue of section 802(b) of theAct.

Please confirm that section 802.4 of the Rules exemptacquisitions by the Partnership of any amount of the Trust's voting securities.If you have any questions about this matter, please do not hesitate to contactus. Thank you.

Very truly yours,

(redacted)