EFTA Document EFTA01377824

ti- I/A The Registrant believes the offers, sales, and issuances of the above securities, including the transaction described under the title "Common Stock Issuances," were exempt from registration under the Securities Act by virtue of Section 4(a)(2), formerly 4(2), of the Securities Act, because the issuance of securities to the recipients did not involve a public offering, or were offered in reliance on Rule 701 because the transactions were pursuant to compensatory benefit plans or contr