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Date
Rule
801.2, 803.9
Staff
Michael Verne
Response/Comments
See comments below

Question

From: (redacted)

Sent: Monday, December 20, 2002 4:19 PM
To: Michael Verne
Subject: HSR question

Mike,

I have a quick question:

Is the following transaction subject to HSR:

We acquire $8 million of voting securities and $52 million of non-voting preferred stock (convetible into non-voting common). Staff comment not reportable.

Who pays the filing fee (regardless of the type or form of transaction)? Staff comment acquiring person

Thanks for your help.

About Informal Interpretations

Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

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