8603012 Informal Interpretation

(redacted)

March 28, 1986
Wayne Kaplan, Esq.
Federal Trade Commission
Room 301
Washington, D.C. 20580

Re: Transfer of Interest in (redacted)
(redacted) A Joint Venture

Dear Mr. Kaplan:

This letter is intended to amend the letter to you from (redacted) of this office dated March 19, 1986. (Redacted) will not be acquiring any interest in (redacted), as stated in the next to last paragraph on page 2 of the letter. Rather, (redacted) a wholly owned subsidiary of (redacted) proposes to transfer (redacted) 50% of its interest in (redacted) limited partnership. This transfer involves neither an asset nor a voting security, and therefore, does not trigger the reporting requirements under the Hart-Scott-Rodino Antitrust Improvements Act of 1976.

Very truly yours,

(redacted)

(redacted)