1302006 Informal Interpretation

Michael Verne

   The relevant number is $200 million, so it is exempt under 802.3


From: (Redacted)

Sent:Tuesday, February 19, 2013 3:47

To:Verne, B. Michael(MVERNE@ftc.gov); Walsh, Kathryn(kwalsh@ftc.gov)

Subject: 802.3 Exemption

Hi Mike and Kate.

Company A plans to acquirea 1/3 interest in oil reserves for $200 million. Is this exempt under802.3 because it doesnot meet the $500 millionthreshold? Or is the relevant number the full value of the oil reserves ;e.g., $600 million?

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