9505013 Informal Interpretation

May 24, 1995

VIA HAND DELIVERY

Richard B. Smith, Esquire
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
600 Pennsylvania Avenue, NW, Room 303
Washing ton, D.C. 20580

Re: (redacted)

Dear Dick :

I am writing to confirm our telephone conversation of May 23, 1995, in which we discussed whether the (redacted) of the (redacted) is a person under the Hart-Scott-Rodino Antitrust Improvements Act of 1976, 15 U.S.C. 18a (the Act). Based on your review of the attachment hereto, particularly sections 2.5 and 5 of the annotations, you agreed that (redacted) is not a person for the purposes of 16 C.F.R. 801.1(a)(2). Therefore any acquisition or divestiture directly by The (redacted) would not be a reportable event under the Act.

We have advised The (redacted) that any acquisition by it is not a reportable event under the Act. If this letter misstates anything we discussed, please call me.

Very truly yours,

(redacted)

Enclosure

cc: (redacted)