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Letter is incorrect. I cannot bind the Commission. I merely advised (redacted) that we advise that no filing is necessary. We refers to the premerger office, and the FTC and Dept. of Justice are not...

I concur. Patrick 9/23/86

9/10/86 Transaction would be scrutinized carefully by PMN Office because structure of transaction lends itself easily to evasion of reporting requirement and it may occur in cases where there could be...

OK. I concur. Called 9-17-86

No Comments

If bonafide financing deal this is exempt under 802.63. AS W.K. concurs.

No written response will be given. A must determine in good faith fair market value of the v.s. of X it will obtain and if below $15.0MM in value then none of above transactions appear to be...

I concur Patrick Sharpe. Called (redacted) 8-22-86 Andy concurs. Upon later review, the letter appears to ignore the PMN position that any direct assumption of liabilities bargained for between the...

See Page 3 for Graphic Illustration

This transaction (or transactions) exempt under 802.20 Called (redacted) 8-26-86

[W]hat (redacted) collects in excess of receivables less reserve for bad debt will be for (redacted) account. (Redacted) has to guarantee the receivables. It sounds to me like (redacted) is acquiring...

No Comments

Response: Advised the Above on Aug. 1, 1986 that I agree. Andy Upon later review this appears to be in error regarding the submission of documentary info. for that portion of the transaction subject...