[Federal Register Volume 65, Number 245 (Wednesday, December 20, 2000)]
[Notices]
[Pages 79861-79865]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 00-32394]


=======================================================================
-----------------------------------------------------------------------

FEDERAL TRADE COMMISSION

[File No. 001 015; Docket No. C-3989]


America Online, Inc., and Time Warner Inc.; Analysis To Aid 
Public Comment

AGENCY: Federal Trade Commission.

ACTION: Proposed consent agreement.

-----------------------------------------------------------------------

SUMMARY: The consent agreement in this matter settles alleged 
violations of federal law prohibiting unfair or deceptive acts or 
practices or unfair methods of competition. The attached Analysis to 
Aid Public Comment describes both the allegations in the draft 
complaint that accompanies the consent agreement and the terms of the 
consent order--embodied in the consent agreement--that would settle 
these allegations.

DATES: Comments must be received on or before January 16, 2001.

ADDRESSES: Comments should be directed to: FTC/Office of the Secretary, 
Room H-159, 600 Pennsylvania Avenue, NW., Washington, DC 20580.

FOR FURTHER INFORMATION CONTACT: Richard Parker, FTC/H-374, 600 
Pennsylvania Avenue, NW., Washington, DC 20580. (202) 326-2574.

SUPPLEMENTARY INFORMATION: Pursuant to section 6(f) of the Federal 
Trade Commission Act, 38 Stat. 721, 15 U.S.C. 46, and section 2.34 of 
the Commission's Rules of Practice (16 CFR 2.34), notice is hereby 
given that the above-captioned consent agreement containing a consent 
order to cease and desist, having been filed with and accepted, subject 
to final approval, by the Commission, has been placed on the public 
record for a period of thirty (30) days. The following Analysis to Aid 
Public Comment describes the terms of the consent agreement, and the 
allegations in the complaint. An electronic copy of the full text of 
the consent agreement package can be obtained from the FTC Home Page 
(for December 14, 2000), on the World Wide Web, at http://www.ftc.gov/os/2000/12/index.htm A paper copy can be obtained from the FTC Public 
Reference Room, Room H-130, 600 Pennsylvania Avenue, NW., Washington, 
DC 20580, either in person or by calling (202) 326-3627.
    Public comment is invited. Comments should be directed to: FTC/
Office of the Secretary, Room H-159, 600 Pennsylvania Avenue, NW., 
Washington, DC 20580. Two paper copies of each comment should be filed, 
and should be accompanied, if possible, by a 3\1/2\ inch diskette 
containing an electronic copy of the comment. Such comments or views 
will be considered by the Commission and will be available for 
inspection and copying at its principal office in accordance with 
section 4.9(b)(6)(ii) of the Commission's Rules of Practice (16 CFR 
4.9(b)(6)(ii)).

Analysis of Proposed Consent Order To Aid Public Comment

I. Introduction

    The Federal Trade Commission (``Commission'') has accepted for 
public comment from America Online, Inc. (``AOL'') and Time Warner Inc. 
(Time Warner'') (collectively ``Proposed Respondents'') an Agreement 
Containing Consent Orders (``Proposed Consent Agreement''), including 
the Decision and Order (``Proposed Order''). The Proposed Respondents 
have also reviewed a draft complaint. The Commission has now issued the 
complaint and an Order to Hold Separate (``Hold Separate Order''). The 
Proposed Consent Agreement intends to remedy the likely anticompetitive 
effects arising from the merger of AOL and Time Warner.

II. The Parties and the Transaction

    AOL is the world's leading internet service provider (``ISP''), 
providing access to the internet for consumers and businesses. AOL 
operates two ISPs: America Online, with more than 25 million members; 
and CompuServe, with more than 2.8 million members. AOL also owns 
several leading Internet products including AOL Instant Messenger, ICQ, 
Digital City, MapQuest, and MoviePhone; the AOL.com and Netscape.com 
portals; the Netscape 6, Netscape Navigator and Communicator browsers; 
and Spinner.com and NullSoft's Winamp, leaders in Internet music.
    Time Warner is the nation's second largest cable television 
distributor, and one of the leading cable television network providers. 
Time Warner's cable systems pass approximately 20.9 million homes and 
serve approximately 12.6 million cable television subscribers, or 
approximately 20% of U.S. cable television households. Time Warner, or 
its principally owned subsidiaries, owns leading cable television 
networks, such as HBO, Cinemax, CNN, TNT, TBS Superstation, Turner 
Classic Movies and Cartoon Network.
    Time Warner also owns, directly or through affiliated businesses, a 
wide conglomeration of entertainment or media businesses. Time Warner's 
holdings include leading magazine franchises, such as Time, People and 
Sports Illustrated; copyrighted music from many of the world's leading 
recording artists that it produces and distributes through a family of 
established record labels, such as Warner Bros. Records, Atlantic 
Records, Elektra Entertainment and Warner Music International; the 
unique and extensive film and animation libraries owned or managed by 
Warner Bros. and New Line Cinema; and trademarks, such as the Looney 
Tunes characters, Batman and The Flintstones; the WB Network, a 
national broadcasting network; and Internet websites, such as CNN.com. 
Time Warner is the majority owner of Road Runner (the trade name of 
ServiceCo, LLC), the second largest provider of cable broadband ISP 
service in the U.S., serving more than 1.1 million subscribers. Road 
Runner has an exclusive contract to provide cable broadband ISP service 
via Time Warner's cable systems through December 2001.
    On January 10, 2000, AOL and Time Warner entered into an Agreement 
and Plan of Merger (the ``merger''), pursuant to which Time Warner 
common stockholders will receive 1.5 shares of the combined AOL Time 
Warner (``combined company,'' or ``AOL Time Warner'') for each share of 
Time Warner common stock they hold. AOL common stockholders will 
receive one share of common stock of AOL Time Warner for each share of 
AOL common stock they hold.

III. The Proposed Complaint

    According to the complaint the Commission intends to issue, AOL's 
merger with Time Warner will have anticompetitive effects in three 
relevant product markets: (1) The market for broadband Internet access; 
(2) the market for residential broadband Internet transport services, 
or last mile access; and (3) the market for interactive television 
(``ITV'') services.
    AOL is the dominant narrowband ISP. Its narrowband customer base 
positions AOL to become a significant broadband ISP competitor as well. 
Time Warner provides broadband Internet access through Road Runner, a 
partially owned subsidiary in which it has a controlling interest. AOL 
and Road Runner are two of the most significant broadband ISP

[[Page 79862]]

competitors in Time Warner cable areas. According to the Commission's 
draft complaint, the relevant broadband ISP markets are or are likely 
to become highly concentrated as a result of the merger, and the merger 
will increase the ability of the combined firm to unilaterly exercise 
market power in Time Warner cable areas and throughout the United 
States. Moreover, new entry is not likely to be timely or sufficient to 
prevent the combined firm from exercising market power.
    In the market for broadband Internet transports services, the 
Commission's complaint alleges that cable television lines and digital 
subscriber lines (``DSL'') are the two principal means of providing 
last mile access for broadband ISPs to the customers. Satellite and 
fixed wireless technologies also provide last mile access, but 
consumers do not view them as viable alternatives for DSL or cable 
broadband access. Currently, AOL's principal means of providing 
broadband access to its subscribers is through DSL, and every broadband 
subscriber it signs represents a lost revenue opportunity for cable 
broadband providers. AOL's merger with Time Warner will reduce its 
incentives to promote and market broadband access through DSL in Time 
Warner cable areas, adversely affecting DSL rollout in those areas and 
nationally, and will increase AOL Time Warner's ability to exercise 
unilateral market power in those areas.
    According to the Commission's complaint, ITV combines television 
programming with Internet functionality. Cable television lines have 
distinct competitive advantages over DSL in providing ITV services to 
broadband customers. AOL recently launched AOL TV, a first generation 
ITV service, and is well positioned to become the leading ITV provider. 
Local cable companies will play the key role in enabling the delivery 
of ITV services. After the merger, AOL Time Warner will have incentives 
to prevent or deter rival ITV providers from competing with AOL's ITV 
service. Thus, the merger could enable AOL to exercise unilateral 
market power in the market for ITV services in Time Warner cable areas, 
which also affects the ability of ITV providers to compete nationally.

IV. Terms of the Proposed Order

    The Proposed Order is effective for a term of five years and 
resolves the Commission's antitrust concerns with the merger as 
discussed below.
A. Broadband Internet Access Services
    Under the terms of the Proposed Order, before Time Warner can make 
AOL's broadband ISP service available in certain identified cable 
divisions representing over 70 percent of Time Warner's cable customers 
(``Identified Cable Divisions''),\1\ Time Warner must first make 
available cable broadband service offered by Earthlink, Inc. pursuant 
to an agreement between Time Warner and Earthlink that the Commission 
has evaluated and approved.
    In addition, Respondents cannot begin to advertise or promote AOL's 
broadband ISP service to subscribers in a cable division until 
Earthlink's competing ISP service is available to subscribers in that 
cable division or Earthlink advertises or promotes its service in that 
cable division, whichever occurs first. These provisions ensure that a 
competing ISP service, which is not affiliated with AOL Time Warner, is 
available to subscribers in most Time Warner cable areas at the same 
time that AOL introduces its cable broadband ISP service. It does not 
prevent Time Warner from conducting tests involving a limited number of 
subscribers that are purely for technological and operational 
implementation purposes, rather than for commercial purposes.
---------------------------------------------------------------------------

    \1\ The identified cable divisions to which this provision 
applies are: New York City, Tampa Bay, Central Florida, Houston, 
Raleigh/Fayetteville, Western Ohio, Northern Ohio, Charlotte, Los 
Angeles, Milwaukee, Greensboro, Hawaii, Cincinnati, San Antonio, 
Syracuse, Kansas City, South Carolina, Columbus, Rochester, Albany, 
and any other cable division with 300,000 subscribers or more that 
is controlled by Respondents.
---------------------------------------------------------------------------

    Within 90 days of making AOL's broadband ISP service available to 
subscribers, Time Warner must enter into agreements to carry at least 
two other non-affiliated broadband ISPs to provide cable broadband ISP 
services in the Identified Cable Divisions. The non-affiliated ISPs, 
and Time Warner's agreements with them, must receive the prior approval 
of the Commission. If Time Warner fails to enter into such agreements 
within this time period, the Commission may appoint a trustee who will 
have the authority to enter into such agreements on Time Warner's 
behalf. These agreements must also receive the prior approval of the 
Commission. These agreements must be on terms comparable to either the 
Earthlink agreement, or any agreement between AOL and another cable 
system to provide AOL's cable broadband ISP service over that cable 
system.\2\
---------------------------------------------------------------------------

    \2\ This provision applies to the following cable systems: 
Adelphia, AT&T, Cablevision, Charter, Comcast, and Cox.
---------------------------------------------------------------------------

    In Time Warner's other cable divisions, Time Warner must enter into 
cable broadband ISP service agreements that have received the prior 
approval of the Commission with at least three other non-affiliated 
ISPs that have received the prior approval of the Commission within 90 
days of making AOL's cable broadband ISP service available in each such 
division. If Time Warner fails to enter into such agreements within 
this time period, the Commission may appoint a trustee who will have 
the authority to enter into such agreements, which will be subject to 
the prior approval of the Commission. These agreements must be on terms 
comparable to either another alternative cable broadband ISP service 
agreement between a broadband ISP and the Proposed Respondents approved 
by the Commission, or any agreement between AOL and another cable 
system to provide AOL's cable broadband ISP service over that cable 
company's system.
    The Proposed Order requires Time Warner to include several 
provisions in the agreements it negotiates with the non-affiliated 
ISPs. Specifically:
     Time Warner must include a most favored nation (``MFN'') 
clause in all alternative cable broadband ISP service agreements 
submitted to the Commission for approval. The MFN must provide that if 
AOL executes a cable broadband ISP service agreement with another cable 
system operator, Respondents must provide a copy of the agreement with 
that cable system operator to a Monitor Trustee appointed by the 
Commission; give notice of the execution of the agreement to each non-
affiliated ISPs that is a party to an alternative cable broadband ISP 
service agreement approved by the Commission; and give the non-
affiliated ISPs the ability to convert to all of the rates and terms in 
the cable system operator's agreement;
     Time Warner must also include in all alternative cable 
broadband ISP service agreements submitted to the Commission for 
approval a requirement that if Proposed Respondents makes available 
different levels of service to their affiliated ISPs, they must make 
those levels of service available to non-affiliated ISPs;
     Time Warner must also include in all alternative cable 
broadband ISP service agreements submitted to the Commission for 
approval a requirement that if Proposed Respondents make available any 
network flow monitoring data or usage accounting to any of their 
affiliated ISPs, they must make that same data or accounting available 
to non-affiliated ISPs;
     Time Warner must also include in all alternative cable 
broadband ISP service agreements, at the option of the non-affiliated 
ISP, a requirement that

[[Page 79863]]

disputes concerning compliance with the rates, terms, and conditions of 
that agreement shall be submitted to binding arbitration; and
     If requested by a non-affiliated ISP, Time Warner must 
provide the nonaffiliated ISPs with the same point of connection within 
Time Warner's cable divisions that Time Warner provides to affiliated 
ISPs. This provision is intended to ensure that Time Warner may not 
discriminate against non-affiliated ISPs by providing them with a less-
advantageous connection point to its network than it provides to AOL.
    If any of the alternative cable broadband ISP service agreements 
approved by the Commission is for a term that terminates prior to 
expiration of the Proposed Order (i.e., five years from the date the 
Proposed Order becomes final), the Proposed Order requires Time Warner 
to enter into an additional alternative cable broadband ISP service 
agreement with a nonaffiliated ISP, subject to the Commission's 
approval, that must take effect immediately upon the expiration of the 
original agreement. If the original alternative cable broadband ISP 
service agreement is for a term of at least three years, Time Warner 
must offer the non-affiliated ISP that is a party to that agreement an 
option to renew the agreement for at least two years.
    If Time Warner terminates any of the alternative cable broadband 
ISP service agreements approved by the Commission before the expiration 
of the Proposed Order, the Proposed Order requires Time Warner to enter 
into an additional alternative cable broadband ISP service agreement 
with a non-affiliated ISP, subject to the Commission's approval, which 
must take effect immediately upon the expiration of the original 
agreement.
    If any non-affiliated ISP terminates its alternative cable 
broadband ISP service agreement approved by the Commission before the 
expiration of the Proposed Order, or if the non-affiliated ISP ceases 
to make its ISP service available to subscribers in a particular 
identified cable division, Time Warner must enter into an additional 
alternative cable broadband ISP service agreement with a non-affiliated 
ISP, subject to the Commission's approval, within 90 days after the 
original non-affiliated cable broadband ISP service is no longer 
available to subscribers.
    In addition to the broadband ISP service agreements described 
above, the Proposed Order also requires Time Warner to negotiate and 
enter into arms' length, commercial agreements with any other non-
affiliated ISP that seeks to provide cable broadband ISP service on 
Time Warner's cable system. Time Warner may decline to enter into such 
negotiations or agreements or impose rates, terms, or conditions based 
on cable broadband capacity constraints, other cable broadband 
technical limitations, or cable broadband business considerations, but 
only so long as it makes such determinations without discrimination on 
the basis of affiliation and not on the basis of the impact on Proposed 
Respondents' ISPs (including, but not limited to a decrease in 
subscribers of Proposed Respondents' ISPs).
    The purpose of these provisions is to ensure that a full range of 
content and services from non-affiliated ISPs is available to 
subscribers; prevent discrimination by Proposed Respondents as to non-
affiliated ISPs on the basis of affiliation, which would interfere with 
the ability of the non-affiliated ISP to provide a full range of 
content and services; and remedy the lessening of competition in the 
market for broadband ISP service as alleged in the Commission's 
complaint.
B. Interactive Television and Other Internet Services
    Section III of the Proposed Order prohibits Time Warner from 
interfering in any way with content passed along the bandwidth 
contracted for and being used by non-affiliated ISPs in compliance with 
their agreements with Proposed Respondents. The Proposed Order also 
prohibits Time Warner from discriminating on the basis of affiliation 
in the transmission or modification of content that Time Warner has 
contracted to deliver to subscribers over its cable systems. The 
Proposed Order specifically prohibits Time Warner from interfering with 
the ability to a subscriber to use, in conjunction with ITV services 
provided by a non-affiliated entity, interactive signals, triggers, or 
other content that the Proposed Respondents have agreed to carry. If 
Time Warner has agreed to transmit ITV signals or interactive triggers 
that AOL subscribers can use, it cannot block transmission of such ITV 
signals or triggers to subscribers using a competing ITV service. In 
addition, the Proposed Order prohibits the Proposed Respondents from 
entering into any agreement with any other cable system that would 
interfere with the ability of the other cable system to enter into 
agreements with non-affiliated ISPs or ITV providers.
    The Proposed Order also requires the Proposed Respondents to 
provide the Commission with all complaints from any non-affiliated 
broadband ISP relating to the failure of the Proposed Respondents to 
make content available. The Proposed Order also requires the Proposed 
Respondents to notify the Commission whenever a television programmer 
complains that the Proposed Respondents have failed to carry 
interactive triggers, signals or content through its cable systems.
C. Broadband Transport Services
    Section IV of the Proposed Order requires AOL to charge the same or 
comparable price for its DSL service to subscribers in Time Warner 
cable areas where AOL cable broadband ISP service or Road Runner is 
available as AOL charges for its DSL service in areas in which neither 
AOL cable broadband ISP service nor Road Runner is available. However, 
AOL may charge different prices for its DSL service to the extent such 
pricing differences reflect any actual cost differences for DSL 
transmission services. The Proposed Respondents must include a 
description of these cost differences in the reports they are required 
to submit to the Commission.
    The Proposed Order also requires AOL to market and promote its DSL 
services to subscribers in Time Warner cable areas where AOL cable 
broadband ISP service or Road Runner is available at the same or 
comparable level and in the same or comparable manner as it markets and 
promotes DSL services to subscribers in areas in which neither AOL 
cable broadband ISP service nor Road Runner is available.
D. Monitor Trustee Provisions
    The Proposed Consent Order authorizes the Commission to appoint a 
Monitor Trustee to monitor compliance with the Order at any time after 
the Proposed Respondents sign the Consent Agreement. The Proposed 
Consent Order provides the Monitor Trustee with the power and authority 
to monitor the Proposed Respondents' compliance with the terms of the 
Proposed Consent Order, and full and complete access to personnel, 
books, records, documents, and facilities of the Proposed Respondents 
to fulfill that responsibility. In addition, the Monitor Trustee may 
request any other relevant information that relate to the Proposed 
Respondents' obligations under the Proposed Consent Order. The Proposed 
Consent Order precludes Proposed Respondents from taking any action to 
interfere with or impede the Monitor Trustee's ability to perform his 
or her responsibilities or to monitor compliance with the Proposed 
Consent Order.

[[Page 79864]]

    The Monitor Trustee may hire such consultants, accountants, 
attorneys, and other assistants as are reasonably necessary to carry 
out the monitor Trustee's duties and responsibilities. The Proposed 
Consent Order requires the Proposed Respondents to bear the cost and 
expense of hiring these assistants.
E. Trustee Provisions
    The Proposed Consent Order provides that the Commission may appoint 
a trustee to enter into broadband agreements with non-affiliated ISPs 
in two instances. First, if the Proposed Respondents have failed to 
enter into agreements with two additional ISPs in the Identified Cable 
Divisions within 90 days of making an affiliated ISP available to 
subscribers, the Commission may appoint a trustee to enter into an 
agreements, subject to the prior approval of the Commission. The 
trustee shall, for an additional 90 days, offer to enter into 
agreements with non-affiliated ISPs that are comparable, taken as a 
whole, to (1) the Earthlink agreement; or (2) any broadband agreement 
AOL enters into with any other cable system operator. The trustee's 
obligation is to ensure that at least two non-affiliated ISPs are 
available on the Time Warner system in these divisions in addition to 
Earthlink.
    The Commission may also appoint a trustee to enter into agreements 
in other time Warner cable divisions if the Proposed Respondents fail 
to enter into agreements with at least three non-affiliated ISPs that 
the Commission approves within 90 days of making any affiliated ISP 
available. The trustee shall, for an additional 90 days, offer to enter 
into agreements with non-affiliated ISPs that are comparable, taken as 
a whole, to (1) any other broadband agreement with a non-affiliated ISP 
for carriage on any Time Warner cable system; or (2) any broadband 
agreement AOL enters into with any other cable system operator. The 
trustee's obligation is to ensure that at least three non-affiliated 
ISPs are available on the Time Warner cable systems in these divisions.
F. Order to Hold Separate
    In addition to the Proposed Order, the Commission also issued an 
Order to Hold Separate (``Hold Separate Order''). The purpose of the 
Hold Separate Order is to prevent interim harm to competition and to 
prevent AOL from gaining a competitive first mover advantage through a 
relationship with Road Runner.
    The Hold Separate Order requires the Proposed Respondents to hold 
AOL and Road Runner separate in each Identified Cable Division until 
they have made an affiliated ISP available to broadband customers in 
that Identified Cable Division. The Hold Separate Order expressly 
prohibits AOL and Road Runner from, among other things, cross or joint 
promotional activities, joint or cooperative advertising, and any steps 
to benefit, directly or indirectly, from each other's business 
activities.
    The Commission may appoint a trustee to monitor compliance with the 
terms of the Hold Separate Order.

V. Opportunity for Public Comment

    The Proposed Consent Agreement has been placed on the public record 
for 30 days for receipt of comments by interested persons. Comments 
received during this period will become part of the public record. 
After thirty days, the Commission will again review the Proposed 
Consent Agreement and the comments received and will decide whether or 
not to make the Proposed Order final.
    By accepting the Proposed Agreement subject to final approval, the 
Commission anticipates that the competitive problems alleged in the 
complaint will be resolved. The purpose of this analysis is to invite 
public comment on the Proposed Consent Agreement, to aid the Commission 
in its determination of whether it should make final the Proposed Order 
contains in the agreement. This analysis is not intended to constitute 
an official interpretation of the Proposed Order, nor is it intended to 
modify the terms of the Proposed Order in any way.

    By direction of the Commission.
Donald S. Clark,
Secretary.

Concurring Statement of Commissioned Mozelle W. Thompson

    The Commission voted today to accept the proposed consent in 
America On Line, Inc./Time Warner Inc., File Number 001-0105. This 
merger marks the first, and potentially most significant convergence of 
an Internet giant with a media, entertainment and cable conglomerate. 
Because it will form a broadband Internet powerhouse spanning the three 
market tiers of content, consumer interface, and broadband conduit, it 
may also shape the very contours of the market for high speed internet. 
In reviewing the merger, I have been concerned that without relief, the 
transaction would have threatened the significant open market 
environment that high technology and Internet companies, innovators, 
and consumers enjoy. I voted to accept the settlement, however, because 
the consent will not only provide a means to address these concerns, 
but will also sent an important message to the market that high speed 
internet should continue to provide consumers with choice of service 
and diversity of content.
    It is important to note that our remedy does give me pause for 
several reasons. First, the remedy--as some might observe--appears to 
be an unusually regulatory solution for a merger order. I generally 
prefer the divestiture of an ongoing business--i.e., structural 
relief--to restore lost competition, a policy that the Commission has 
increasingly favored when settling merger cases.\1\ Moreover, it is 
difficult to determine whether the order's five-year duration is too 
limited to accomplish the full goal of the relief.
---------------------------------------------------------------------------

    \1\ In matters such as this, where the parties repeatedly failed 
to articulate how the merger would benefit consumers, I tend to 
believe structural relief--or outright challenge of the merger--is 
even more warranted to preserve the public interest.
---------------------------------------------------------------------------

    Second, I am concerned that the Commission's open access relief 
might not preclude the possibility of harm from the merged entity's 
control of AOL and Time Warner content along with the Time Warner cable 
systems. The settlement nonetheless marks an important first step for 
future open competition on cable for Internet service providers and 
content providers. The relief provides that the Commission will 
supervise AOL Time Warner's conduct for five years; but it tells the 
market to continue to demand openness and competition in this important 
area. I note that the negotiated relief was improved from the 
companies' earliest proposals.
    That being said, I also hope that the public does not over-
interpret today's decision; despite the fact that this merger has been 
allowed to proceed without challenge, I expect that the Commission will 
scrutinize future Internet mergers as it does any merger--on a case-by-
case basis. Moreover, the Commission will continue to exercise its 
antitrust responsibilities by taking appropriate action against anti-
competitive behavior. Finally, though many interested parties will, no 
doubt, scrutinize the terms of the order ISP access agreements, these 
should not necessarily be seen as a template for future Internet 
access, but should instead be regarded as examples of how the public 
should share the benefits provided by the principles of Internet 
openness and diversity.

[[Page 79865]]

    For those reasons, I concur with accepting the proposed consent 
orders.

[FR Doc. 00-32394 Filed 12-19-00; 8:45 am]
BILLING CODE 6750-01-M