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We would view this as an operating unit sot 801.2(d) would not apply. N. Ovuka concurs.

Exempt under 802.30

You would be looking at all of the assets of the LLC and any other entities it controls. Exempt assets do not reduce the size of transaction in an acquisition of partnership interests, but are used to...

Each would be a separate secondary acquisition and could (assuming the percentages are low enough) qualify for either of these exemptions.