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Date
Rule
801.1(b)
Staff
Andrew Scanlon
Response/Comments
4/22/87 Advised that I concur with the conclusion drawn by the letter & am unable underthe policy of the office to confirm in writing AMS

Question

(redacted)

April 15, 1987

Andrew Scanlon
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
6th & Pennsylvania Avenue, NW
Room 303
Washington, D.C. 20580

Re: Federal Trade Commission Transaction Number (redacted) Notification
And Report Form for Certain Mergers and Acquisitions dated
February 17, 1987 Filed by (redacted)

Dear Mr. Scanlon:

This letter is being sent to you with regard to a Notification and Report Form for Certain Mergers and Acquisitions , dated February 17, 1987, which was filed on February 18, 1987 and amended by letter dated February 19, 1987 (the form, as amended, hereinafter referred to as the Form). The Form was filed by (redacted) on behalf of International (redacted). (International) its ultimate parent entity at that time. The acquiring person designated in the Form was (redacted)

The purpose of this letter is to inform you that (redacted) is no longer controlled by International within the meaning of 16 code of Federal Regulations 801.1(b). Furthermore, the acquisition described in the Form has not yet been completed. Accordingly, (redacted) not International, is now the acquired person.

We have been advised by (redacted) of your office (in a conversation on April 6, 1987 with (redacted) of our office that with your receipt of the following information (redacted) will not have to make any further filing prior to completing the transaction described in the Form.

Mr. Kaplan has confirmed to us that so long as the transaction described in the Form has not changed no additional filing is required because (i) the information in any new filing would be the same as in the Form, (ii) the antitrust analysis would be the same, and (iii) the entity certifying the Form, (redacted) is now the acquired person.

We would appreciate your written confirmation that under these circumstances there is no obligation upon (redacted) and (redacted) to file a new form. Accordingly, if you concur, please sign the extra copy of this letter in the space indicated below and return it to us, in the enclosed pre-addressed envelope.

If you have any questions regarding this matter, please contact the undersigned.

Yours truly

(Redacted)

(Redacted)

cc:(redacted)

Confirmed in accordance
with the foregoing on
April ________, 1987


 

____________________

Andrew Scanlon for the
Federal Trade Commission

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