Question
From: (redacted)
Sent: Friday, April 01, 2005 10:42 AM
To: Verne, B. Michael
Subject: HSR inquiry
Mr. Verne,
We represent a client who holds close to the threshold HSR amount of a certain company's voting stock, and our clientperiodically makes purchases of additional stock on the open market. We aretrying to determine the value of the stock our client already owns and thevalue of stock about to be acquired. Because the client purchases large blocksof stock on the open market, they receive discounts and pay less than thecurrently traded price. Is the stock about to be purchased then valued at thecurrent market price or at the discounted price to be paid under the HSR rules?
Also, for the stock already held, is it valued at yesterday's closing price orbased on some other method of valuation?
Any advice you can offer will be greatly appreciated. Thank you, and if youhave further questions regarding my inquiry or if it would be easier to discussthis on the phone, please let me know and I can call you or feel free to callme at the number below. I look forward to your response.