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Date
Rule
Form Item 4(c)
Staff
Michael Verne
Response/Comments
You need only produce 4(c) documents related to the exercise of the option in 2006.

Question

From: (redacted)

Sent: Wednesday,March 08, 2006 5:47 PM

To: Verne,B. Michael

Subject: 4(c)Question

Ourclient has a question as to whether it needs to produce 4(c) documents relatedto a past, related transaction.

In2000, our client acquired 49% of a noncorporate entity and an option topurchase the remaining 51%. The transaction was not reportable at the time, butdocuments with 4(c) subject matter were created to analyze the acquisition.

In2006, our client exercised the option to acquire the remaining 51 % of the noncorporateentity and now must report the transaction. Must our client produce documentswith 4(c) subject matter that were created in 2000 to analyze the 2000transaction?

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