Securities Exchange Act of 1934
Rule 12g3-2(b)

July 31, 2007

Response of the Office of International Corporate Finance
Division of Corporation Finance

You have requested the Division's views with respect to whether foreign private issuers whose securities are traded through the PORTAL® Market operated by the Nasdaq Stock Market LLC would continue to be eligible under the exemption provided under Rule 12g3-2(b) under the Securities Exchange Act of 1934 because that market may be deemed an "automated inter-dealer quotation system" for purposes of the exclusion under Rule 12g3-2(d)(3). On the basis of the representations made in your letter, it is the position of the Division that a foreign private issuer would continue to be eligible to claim the exemption under Rule 12g3-2(b) notwithstanding that the securities of the issuer are traded through the PORTAL® Market because that market is not deemed to be an "automated inter-dealer quotation system" for purposes of Rule 12g3-2(d)(3).

Because this position is based upon the representations made in your letter, any different facts or conditions might require a different conclusion.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/2007/portal073107-12g32b.htm