Â鶹´«Ã½

July 1, 1992

Patrick Sharpe
Premerger Notification Office
Bureau of Competition
Room 303
Â鶹´«Ã½ Trade Commission
6th Street and Pennsylvania Avenue, N.W.
Washington, D.C. 20580

Dear Mr. Sharpe:

This letter confirms our telephone discussion of June 30, 1992. During said discussion, I inquired into the meaning of Hart-Scott-Rodino Report Item 9 as applied to reporting the formation of a joint venture. Specifically, I asked you whether a joint venturer, in response to Item 9, must report acquisitions of entities which derive revenue in a 4-digit industry listed in the response to Item 7(a) if the proposed joint venture is not reasonably expected to derive revenue in that industry. You answered in the negative.

Sincerely,

(redacted)

cc: (redacted)