December 4, 2000
Michael Verne, Esq.
Federal Trade Commission
Premerger Notification Office
6th Street & Pennsylvania Avenue, NW
Washington, D.C. 20580
Re:Premerger Notification Act - Size of Transaction Determination
Dear Mr. Verne:
I am writing to confirm our conversation last week and tho thank you for your assistance.
During our telephone conference, you answered my question regarding the size of transaction test. Our
client (excess net sales of $100 million) is purchasing 100% of the voting securities of a manufacturing
company (net sales of $18 million). The purchase price for the securities is $7 million. You confirmed
that this transaction does not satisfy Section 7(A)(a)(3)(b).
If the conclusions that I have described in this letter are not consistent with your understanding of the
Act, please contact me at your earliest convenience.
Very truly yours,