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Date
Rule
Item 4(c)
Staff
Michael Verne
Response/Comments
Board minutes can be redacted to supply only the relevant portion. Any other documents can only be redacted on the basis of privilege.

Question

From:(redacted)
Sent:Wednesday, May 26, 2004 3:53 PM
To:Verne, B. Michael
Subject: Item 4(c)Issue

Mike, a client of mine is hesitant to submit the entire minutes of a board ofdirectors meeting because of confidentiality concerns. A few pages of theminutes could otherwise qualify as 4(c) material because there is a discussionof the impact of the transaction. Is it acceptable to simply submit those pagesor does the FTC PNO require the submission of the entire board minutes?

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