0610013 Informal Interpretation

October 11, 2006

VIAFAX (202/326-2624)

ANDFEDERAL EXPRESS

Mr.Michael B. Verne

PremergerNotification Office

Bureauof Competition

FederalTrade Commission Room 303

600 Pennsylvania Avenue, N.W.

Washington, D.C. 20580

DearMike:

This letter is afollow up to my letter dated October 10, 2006 (the "Prior Letter")and clarifies the conclusions reached in our telephone conference that day. Therelevant facts set forth in the Prior Letter remain the same. Capitalized termsnot defined in this letter have the meanings given such terms in the PriorLetter.

Based on the factspresented in the Prior Letter, you concluded that none of LLC, A or B controlsthe Company within the meaning of Rule 801.1(b) and that the Company is its ownultimate parent entity.

Please call me immediately at (redacted)should the position of the Federal Trade Commission staff with regard to thismatter be different from that set forth above. In addition, please retain thisletter in your files, I appreciate very much your assistance and helpful adviceon this matter.