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8/13/91-John Sipple says no filing required but questions raised are somewhatdifficult. However, since Bank A is not selling all, or substantially all, of its creditcard accounts in a given geographic...

I concur PS-called 8-12-91

I concur PS-called 8-12-91

8/12/91-Advised (redacted) that formation of a bona fide partnership is not negotiable under 801.40. Viewing this as a purchase of an interest in non-productive real estate, the transaction is also...

OK-08/09/91 JK

8/9/91 called (redacted) Advised that in no case can 45 day period be earlier thanday before option signal. Would also suggest that 45 day calculation be used foreach day of the 10 days within which...

OK - NO Partnership STAFF COMMENT: Not the test under 802.20 STAFF COMMENT: Seems to be all part of formation PMN Office, not Commission, also below in ref. to FTC

None noted

Pursuant to the 802.1 ordinary course of business exemption for realty the acquisition of proven gas reserves that hasn't begun to produce revenue is exempt.

None noted

[note 1-PMN Office]

None noted

None noted

OK

You do not deduct costs (including subcontracted work) from gross revenues (turnover) in order to derive a figure comparable to net sales. Net sales are gross sales minus returns and allowances -not...

None noted

None noted

Called (redacted) and informed him that this is exempt under C-10 - This is exempt under C-10 See #38 new Premerger Practice Manual. JS concurs. Superimposing a holding company over an operating co...

Called on 7/24/91- Informed the inquirer that we would treat (redacted) as the State or agency of the state of (redacted) since it is an instrumentality of the state, formed by the state for the...

This appears to be ok. It is merely a name change - the form (SIC info) remains the same for the antitrust analysis. PS: RS concurs called (redacted) 7-12-91 and left message