0701001 Informal Interpretation

From:(redacted)

Sent:Monday, January 01, 2007 10:26 PM

To:Verne, B. Michael

Subject:4(c) Question

Mike,

Happynew year.

I understand that in the past the PNO has taken theposition that if a presentation that is otherwise responsive to Item 4(c) waspresented to the board of directors in draft form and then subsequentlyrevised, both the draft and the final version of the presentation must beincluded as 4(c) documents. Does the PNO apply a similar rule to presentationsor other documents that are presented internally in draft and then subsequentlyrevised, if such presentations or other documents were not presented to theboard of directors (e.g., were only presented to officers or employees)? Wouldboth the draft and final versions be 4(c) documents (assuming they areotherwise responsive)?