Rule(s):	801.11(e), 801.1(a)(2)
Staff:	Michael Verne
Response / Comments:	04/23/2012 – Agree.
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From:         (redacted)
Sent:          Monday, April 23, 2012 2:55 PM
To:              Verne, B. Michael
Subject:     Further Question

I was thinking further about our exchange this morning about an LLC owned by a federally recognized Indian tribe being an "entity" within the HSR definition although the Indian tribe itself would not fall within the exemption. I don't see anything precluding the LLC, being newly established, relying on 801.11(e) in its first acquisition when it does not have a balance sheet. Do you agree?