Question
(redacted)
Linda Heban
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
600 Pennsylvania Avenue, NW, Room 303
Washing ton, D.C. 20580
Re: Premerger Notification concerning the proposed acquisition of certain voting securities of (redacted)
Dear Linda:
Late last week, (redacted) received early termination in connection with above-referenced acquisition. Since that time the transaction has been slightly restructured. As you recall (redacted) was to have bought (redacted) (an indirect wholly-owned subsidiary (redacted) ). The only operating entity of (redacted) was its wholly-owned subsidiary, (redacted). The transaction has been restructured so that the voting securities of (redacted) will be bought from (redacted). Just prior to the acquisition of (redacted) individuals, who are currently holders of (redacted) notes, will acquire voting securities of (redacted) from (redacted). No individual will hold in excess of 34% of (redacted).
As I am sure you can see, the information which (redacted) would file as the ultimate parent entity of (redacted) will be identical to the information which (redacted) filed as the ultimate parent entity of (redacted). The information which (redacted) will file will be identical to that which it filed in connection with the above-referenced transaction.
In light of the above, it would seem that no useful purpose would be served by an additional filing and processing of a request for early termination.
Once you have reviewed this letter, would you please call me. Thank you for your cooperation.
Very truly yours,
cc: (redacted)