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Date
Rule
801.10
Staff
Patrick Sharpe
File Number
9610014
Response/Comments
Each of the four are acquiring an asset interest whose fair market value/purchase price is less than $15 MM. These transactions (if they meet the size-of-person test) do not meet the size-of-transaction test. Called (redacted) 10/29 - PS

Question

(redacted)

October 28, 1996

VIA TELEFAX & FIRST CLASS MAIL


Mr. Patrick Sharpe
Federal Trade Commission
Client Specialist
Premerger Notification Office
Bureau of Competition, Room 303
Washington, DC 20580


Dear Mr. Sharpe:


This will confirm our telephone conversation of October 28, 1996, where it was concluded that the following scenario is not reportable under the Hart-Scott-Rodino Antitrust Improvements Act:

Four entities, each of whom may or may not be directly or indirectly an over $100 million and/or over a $10 million person, are jointly acquiring equal interests (25% each) in under $60 million of assets of an over $100 million person.

Thank you for your assistance in this matter.
 

Very truly yours



(redacted)

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