Question
(redacted)
February 19, 1987
Patrick Sharpe
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
600 Pennsylvania Avenue, NW, Room 303
Washing ton, D.C. 20580
Re:
Dear Mr. Sharpe:
This is to confirm our telephone conversation concerning the non-reportability of the following transaction.
The shareholders of corporation X, formed in December of 1986 to acquire the stock of another corporation, hold voting securities of Corporation X in the following percentages: individual A has 43.2% of the voting securities, individuals B and C each have 25.5% of the voting securities and the remaining 5.8% of voting shares are held by a small number of other individuals. Individual A also owns 98% of the voting securities of Corporation Y. Corporation X and Corporation Y engage in unrelated businesses. Corporation X would like to purchase all of the voting securities currently held by individual B and C by corporation X. You have informed me that the acquisition of the voting securities held by B and C by corporation X is an exempt transaction under Section 802.30 of the premerger notification regulations and is therefore not subject to the notification regulations and is therefore not subject to the notification and waiting period requirements.
If the foregoing does not accurately represent our conversation, I would appreciate you contacting me promptly, as there is some urgency in the transaction.
Sincerely,
cc: (redacted)