Question
August 7, 1991
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
600 Pennsylvania Avenue, NW, Room 303
Washington, D.C. 20580
Re:Necessity of filing Hart-Scott-Rodino application for sale and purchase of (redacted) located in (redacted).
Dear Mr. Sharpe:
The purpose of this letter is to memorialize our conversations of August 2 and August 6, 1991 wherein you confirmed my interpretation that, under the statutes, rules and regulations promulgated under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (H.S.R.), no filing would be required for a transaction involving the sale of an office/hotel mixed use complex where the hotel component of such a mixed complex is valued below the $15,000,000 threshold governing asset sale transactions. As I described to you in our conversation, the hotel component of the subject mixed use complex is valued well below said $15,000,000 threshold amount. Specifics of our transaction are as follows:
cc: (redacted)