FTC Seeks Public Comments on Two More Proposed Whole Foods Divestitures, Docket No. 9324, FTC File No. 071 0114 #547292-00037

Submission Number:
547292-00037
Commenter:
mr. james carroll
Organization:
faegre & benson
State:
CO
Initiative Name:
FTC Seeks Public Comments on Two More Proposed Whole Foods Divestitures, Docket No. 9324, FTC File No. 071 0114

Mr. Kenneth Libby Bureau of Competition FTC Office of the Secretary 600 Pennsylvania Avenue N.W. Washington, D.C. 20580 Re: In the Matter of Whole Foods Market, Inc., Docket Number 9324 Dear Mr. Libby: I am writing in support of the efforts of A-M Holdings, LLC to purchase the Whole Foods Market store located at 1651 Broadway in Boulder, Colorado and the intellectual property pertaining to Alfalfa's Markets. I am a corporate lawyer and a partner in the largest law firm located in Boulder County, Colorado. As such, I am very familiar with the business community in the State of Colorado and, more specifically, Boulder. The principals of A-M Holdings are well-known and well-respected serial entrepreneurs in Colorado. They have been involved in the founding and success of many of Boulder's largest and most iconic companies, including CROCs, Horizon Organic Dairy, Celestial Seasonings and Alfalfa's/Wild Oats. They are also industry pioneers in the retailing of organic and natural foods. Boulder would benefit by having more competition in the retailing of natural and organic foods. And so a return of Alfalfa's would be a step in the right direction. But Whole Foods is an extremely large and successful company. Therefore, it will be critically important for the Alfalfa's assets to be acquired by a buyer with substantial financial, industry and entrepreneurial resources. Otherwise, it is unlikely any actual competition in this market will emerge. The principals of A-M Holdings have competed effectively with Whole Foods in the past. I believe, therefore, that they are well-suited to do so again in the future. Thank you very much. /s/ James H. Carroll James H. Carroll Partner Faegre & Benson LLP