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Date
Rule
802.30
Staff
Michael Verne
Response/Comments
Correct.

Question

From:(redacted)

Sent:Wednesday, December 06, 2006 1:00 PM

To:Verne, B. Michael

Subject:Section 802.30

Michael,

Our clientis pursuing a tender offer/going private transaction whereby it is repurchasingits own securities (actually ADRs) and taking itself private, off NASDAQ andfrom SEC reporting requirements. Even though it is purchasing its securitiesfrom third parties (shareholders), because it is purchasing its own securities,I believe it should be exempt under section 802.30. Is this correct?

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