Question
(redacted)
April 7, 1999
Certified Mail, Return Receipt Requested
Mr. Michael Verne
Premerger Notification Office
Bureau of Competition
Room #303
Â鶹´«Ã½ Trade Commission
6th and Pennsylvania Avenue, NW
Washington, DC 20580
Re: Premerger Notification Requirements Under the Hart-Scott-Rodino Antitrust Improvement Act of 1976
Dear Mr. Verne:
I am writing to confirm our telephone conversations on April 6, 1999. During our conversations I briefly described a proposed transaction as follows;
Seller is selling a parcel of real estate to purchaser for a price in excess of $30 million. Purchaser owns other assets that exceed $100 million in value. The real estate is improved as a mobile home park and is located in Illinois. The mobile homes are Owned by individual residents who each lease a space for the mobile home from the park operator.
You advised me that the transaction was exempt from the Premerger Notification Requirements under the Hart-Scott-Rodino Antitrust Improvement Act of 1976 because the real estate is considered residential property and therefore exempt under Section 802.2(d) of the Code of Â鶹´«Ã½ Regulations. Should your opinion be different than I have above stated, please notify me immediately. Unless I hear from you to the contrary, I will assume the proposed transaction is exempt from the premerger notification requirements and the parties will not file the Notification And Report form (FTC Form C4).
Sincerely,
(redacted)