8302003 Informal Interpretation

Item 7(c)(iv)
Patrick Sharpe, Patricia Foster

Concur with all 4 points




February 8, 1983


Mr. Patrick Sharpe
Compliance Officer
Pre-Merger Notification Office
Bureau of Competition
Federal Trade Commission
Room 301
Washington, D.C. 20580

Re:Antitrust Improvement Act Notification and Report Form

(The Form) - Item 7(c)(iv)

Dear Mr. Sharpe:

This letter will serve to set forth my understanding of you

responses to several question discussed by, with respect to

Item 7(c)(iv) of the Form.

Item 7(c)(iv) requires that the filing party must provide

the address, arranged by state, county and city or town, of each

establishment (within the SIC major groups 52-62 and 64-89)

from which it derived dollar revenue in the most recent year,

if any other party to the acquisition also derived dollar

revenue from an establishment within the same SIC major group.

For purposes of the Form, an establishment is defined as any

retail location, location where services are offered or

rendered, or other business location from which dollar revenues

were derived. Fed. Reg. Vol. 43, No. 147, July 31, 1978.

Pursuant to our conversation, it is my understanding that

the following are not establishment which must be reported

under Item 7(c)(iv) of the Form:

1. Properties in which the filing person holds only a

security interest, evidenced by a mortgage, deed of

trust, or similar security instruments;

2. Individual properties owned by companies in which the

filing party holds less than a 50 percent interest;

3. Individual properties owned by limited partnerships in

which the filing party has a general partnership

interest but not a majority equity interest; and

4. Properties which are managed but not owned by the

filing party (these properties are to be distinguished

from the location of the filing partys establishment

which [provides the management services).

Please acknowledge you concurrence with my understanding of

the requirements of the Form, if such is the case, by signing

and returning the enclosed copy of this letter. In the event

that may of the above does not accurately represent the

requirements of the Form, please advise of the modifications

which you believe to be appropriate.

Your assistance in this matter is greatly appreciated, and

if you should have any questions, please contact me.

Best regards.

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