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Called on 10/3 - agree the letter reflects the advice given [note 1-Attachment]

10/2/91 Called (redacted) points support the acquiring persons intent. FTC or DOJ may still investigate to determine actual intent [note 1-the conclusion the acquiring person not the staffs conclusion...

[note 1-The Foreign assets were initially exempt under 802.51(a) although they were included in the initial filing.]

If two regulatory prepared balance sheets or financial statements exist covering the same period, both must be used to determine size. In this case, the GAAP balance sheet (“total assets”) would meet...

None noted

See #139 new PM Practice Manual Agree that you can off set cash equivalent securities -called (redacted) [note 1-cash equivalent]-note 1-Municipal Bonds and other marketable securities]-[note 3-agreed...

Facts indicate that C is an agent of A and therefore, A must first file before acquisition by and through agent C. Otherwise an 801.90 violation will occur re: purpose is to evade filing between A and...

Acquisition of limited partnership interests which are traded on an exchange is reportable only if the interests are voting securities under 801.1(f)(1) of the HSRRules. In this case, they are not...

Advised (redacted) that transaction appeared exempt. While it is possible that buyer may compete in sale of equipment used by lessees which make up 2.9% of transaction, this as a percentage of total...

Under 7A(c)(1) the acquisition of voting stock of a corporation (other than one holding exempt realty) is not exempt even though the acquisition of assets by themselves would be exempt. Under 802.20...

(redacted) says Bank also has Visa and Mastercard. Bank may or may not exit private label credit card business. Customer lists already belong to A. Transaction is exempt as ordinary course of business...

Your letter is too vague. It should be fact specific. I need more details in order to give a definitive answer. Discussed comments about this letter with (redacted) on 9/26/91 [note 1- Premerger...

9/24/91 (redacted) called. No time crunch on matter. Will obtain response to anyquestions and write new letter to me. RBS [note 1: Premerger NotificationOffices]

9/13/91-Advised (redacted) that letter had been reviewed by PMN staff and it was in agreement that Company Bs agreement with X did not pass beneficial ownership of the 13% of As voting stock to B...

9-12-91 Called-If the assets previously filed for are the same and the only assets of the partnership then no new filling needed. If partnership has other assets not previously filed for then a new...

09/06/91-agree w/ the conclusion herein

None noted

None noted

None noted