Question
(redacted)
March 24, 2000
Mr. Patrick Sharp
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
6th and Pennsylvania, N.W., Room 303
Washington, DC 20580
Dear Mr. Sharp:
This letter is to confirm conversations we have recently had with you concerning the necessity of a filing in connection with the acquisition of voting securities of a major league baseball club.
As I indicated to you, upon further review of the current ownership structure, we have concluded that there is no filing required for reasons that are unrelated to baseball's exemption from the antitrust laws. An individual is the acquiring person. That individual is also the ultimate parent entity of the acquired person by reason of his ownership of more than 50% interest in the profits of a limited partnership that in turn owns all of the outstanding voting securities of the baseball club. With this individual as the ultimate parent entity of the acquired person, the acquiring person and the acquired person would be the same and the transaction would be exempt.
Also, there is no holder of voting securities of the baseball club, nor is there anyone who has the contractual power to designate 50% or more of the directors of the baseball club, and therefore, there is no other acquired person in the transaction.
Thank you for your time in this matter.
Very truly yours,
(redacted)