0009008 Informal Interpretation

[redacted]

September 20, 2000

Mr. Michael Verne

Federal Trade Commission

Premerger Notification Office

600 Pennsylvania Avenue, N.W.

Washing ton, D.C. 20580

Re: 16 C.F.R. 802.9

Dear Mr. Verne :

This letter will confirm our telephone conversation of yesterday afternoon in which and I asked whether the collaboration efforts described in the attached sheet would render the "solely for the purpose of investment" exemption in 16 C.F.R. 802.9 inapplicable if one of the companies involved in the collaboration effortwere to buy voting securities of the other. You advised us that you consulted with Mr.Hancock of your office and that neither he nor you through the described collaborative efforts were inconsistent with, or would render inapplicable, the exemptions afforded by 16 C.F.R. 802.9.

We thank you for your assistance in this matter.

Sincerely,

[redacted]

cc: [redacted]