United States versus Greyhound Lines, Inc.; Proposed Final Judgment and Competitive Impact Statement

DEPARTMENT OF JUSTICE

Antitrust Division

United States versus Greyhound Lines, Inc.; Proposed Final

Judgment and Competitive Impact Statement

Notice is hereby given pursuant to the Antitrust Procedures and

Penalties Act, 15 U.S.C. 16(b)-(h), that a proposed Final Judgment,

Stipulation, and Competitive Impact Statement have been filed with the

United States District Court for the District of Columbia, in United

States v. Greyhound Lines, Inc., Civil Action No. 95:CV01852. The

Complaint in this case alleges that lease agreements between Greyhound

and tenant bus companies operating at Greyhound's terminals violate

Section 1 of the Sherman Act. The standard Bus Terminal License

agreement between Greyhound and its tenants prohibits the tenants from

selling tickets within a 25-mile radius of Greyhound's terminal or from

accepting the tickets of other bus companies sold in this area. This

provision is commonly known as the ``25-mile rule.'' The Complaint

alleges that the 25-mile rule restricts competition in the provision of

intercity bus transportation by preventing Greyhound's tenants from

providing connecting service with bus companies operating at other

terminals and from providing bus service from non-terminal facilities,

such as airports and train stations. The Complaint also alleges that

the 25-mile rule restricts competition in the distribution and sale of

tickets for intercity bus transportation.

On September 28, 1995, the United States and Greyhound filed a

Stipulation in which they consented to the entry of a proposed Final

Judgment providing the relief the United States seeks in the Complaint.

The proposed Final Judgment requires Greyhound to remove the 25-mile

rule from its Bus Terminal License agreements within 60 days of the

entry of the Final Judgment. The proposed Final Judgment also enjoins

Greyhound from terminating or discriminating against a tenant in order

to prevent ticket sales outside the Greyhound terminal. Furthermore,

Greyhound is enjoined from entering into exclusive interconnection

agreements with other bus companies.

Public comment is invited within the statutory 60-day comment

period. Such comments and responses thereto will be published in the

Federal Register and filed with the Court. Comments should be directed

to Roger W. Fones, Chief, Transportation, Energy & Agriculture Section,

Antitrust Division, Department of Justice, Room 9104, 555 Fourth

Street, NW., Washington, DC 20001 (telephone: 202-307-6351).

Rebecca P. Dick,

Deputy Director, Office of Operations, Antitrust Division.

United States District Court for the District of Columbia

United States of America, Plaintiff v. Greyhound Lines, Inc.,

Defendant.

[Civil Action No. 95-1852]

Stipulation

It is stipulated by and between the undersigned parties, by their

respective attorneys that:

1. The Court has jurisdiction over the subject matter of this

action and over each of the parties thereto, and venue of this action

is proper in the District of Columbia;

2. The parties consent that a Final Judgment in the from hereto

attached may be filed and entered by the Court, upon the motion of any

party or upon the Court's own motion, at any time after compliance with

the requirements of the Antitrust Procedures and Penalties Act (15

U.S.C. 16), and without further notice to any party or other

proceedings, provided that the Plaintiff has not withdrawn its consent,

which it may do at any time before the entry of the proposed Final

Judgment by serving notice thereof on Defendant and by filing that

notice with the Court;

3. In the event Plaintiff withdraws its consent or if the proposed

Final Judgment is not entered pursuant to this Stipulation, this

Stipulation shall be of no effect whatsoever, and the making of this

Stipulation shall be without prejudice to pay party in this or any

other proceeding.

Dated: September 28, 1995.

For Plaintiff United States of America.

Michael D. Billiel,

Michele B. Felasco,

Attorneys, U.S. Department of Justice, Antitrust Division, 555 Fourth

Street, N.W., Room 9104, Washington, D.C. 20001, (202) 307-6666.

For Defendant Greyhound Lines, Inc.

Mark F. Horning,

Margaret M. Clark,

Steptoe & Johnson, 1330 Connecticut Avenue, N.W., Washington, D.C.

20036-1795, (202) 429-8126.

United States District Court for the District of Columbia

United States of America, Plaintiff. v. Greyhound Lines, Inc.,

Defendant.

[Civil Action No. 95-1852]

Final Judgment

Plaintiff, United States of America, filed its Complaint on

September 28, 1995. Plaintiff and Defendant, by their respective

attorneys, have consented to the entry of this Final Judgment without

trial or adjudication of any issue of fact or law. This Final Judgment

shall not be evidence against or an admission by any party with respect

to any issue of fact or law. Nothing in this Final Judgment shall

constitute an admission by Defendant of any violation of law, liability

or wrongdoing. Therefore, before the taking of any testimony and

without trial or adjudication of any issue of fact or law herein, and

upon consent of the parties, it is hereby

Ordered, adjudged, and decreed, as follows:

I

Jurisdiction

This Court has jurisdiction of the subject matter of this action

and of each of the parties consenting hereto. The Complaint states a

claim upon which relief may be granted against the

[[Page 53203]]

defendant under Section 1 of the Sherman Act, 15 U.S.C. 1.

II

Definitions

As used herein, the term:

(A) ``BTL Agreement'' means the Bus Terminal License Agreement

between Greyhound Lines, Inc., as owner, leaseholder or operator of a

bus terminal, and a tenant carrier.

(B) ``Defendant'' means Greyhound Lines, Inc., each of its

predecessors, successors, divisions, subsidiaries, and affiliates, each

other person directly or indirectly, wholly or in part, owned or

controlled by it, and each partnership or joint venture to which any of

them is a party, and all present and former employees, directors,

officers, agents, consultants or other persons acting for or on behalf

of any of them.

(C) ``Tenant carrier'' means any bus company that is a tenant at a

bus terminal owned, leased or operated by Defendant.

(D) ``Twenty-five (25) Mile Rule'' means that provision in

Greyhound's BTL Agreements that reads substantially as follows:

Subject to Section 1, Licensee agrees that during the term

hereof, it will use the Terminal as its major terminal in the City

of [Name of City] for the aforesaid operations and will not without

the prior written consent of the Company allow or permit any tickets

or busbills to be sold at any other place within a twenty-five (25)

mile radius of the Terminal, other than the Terminal, or honor the

tickets or busbills of any other carrier for such transportation

which are sold within the said twenty-five (25) mile radius.

Notwithstanding the foregoing, tickets or busbills of Licensee may

continue to be sold, and Licensee may honor the tickets or busbills

of other carriers which are sold, at any place within the said

twenty-five (25) mile radius where they are being sold as of the

date of this Agreement. A list of such places where tickets or

busbills of Licensee are sold within the twenty-five (25) mile

radius of the Terminal is appended to this Agreement as Appendix 3.

If Licensee wishes to change any such place of sale of its tickets

or busbills to another place within five (5) miles of such place and

within the said twenty-five (25) mile radius of the Terminal,

Licensee may make such change upon thirty (30) days written notice

to Company. It is further understood that in all of Licensee's bus

schedules and advertising pertaining to its aforesaid operations,

the terminal shall appear as the only place in the City of ________

where tickets or busbills are on sale.

III

Applicability

(A) This Final Judgment applies to the defendant and to each of its

subsidiaries, successors, assigns, officers, directors, employees, and

agents, and to all other persons in active concert or participation

with any of them who receive actual notice of this Final Judgment by

personal service or otherwise.

(B) Nothing contained herein shall suggest that any portion of this

Final Judgment is or has been created for the benefit of any third

party and nothing herein shall be construed to provide any rights to

any third party.

IV

Prohibited Conduct

(A) Defendant is ordered, within 60 days from the date of entry of

this Final Judgment, to remove from each of its BTL Agreements the

Twenty-five (25) Mile Rule. Defendant may comply with this provision by

amending its existing BTL agreements to remove the Twenty-five (25)

Mile Rule or by terminating such Agreements and negotiating new

agreements not containing the Twenty-five Mile Rule.

(B) Defendant is restrained and enjoined from:

1. conditioning access to its terminals, directly or indirectly,

upon a tenant carrier agreeing not to: (i) sell its tickets or busbills

at locations other than the Greyhound terminal, or (ii) honor the

tickets or busbills of another carrier sold at such other locations.

2. terminating or threatening to terminate any BTL Agreement where

the purpose or effect of such termination or threat of termination is

to prohibit a tenant carrier from (i) selling its tickets or busbills

at locations other than the Greyhound terminal, for transportation

services using that Greyhound terminal or a terminal or facility that

is competitive with such Greyhound terminal, or (ii) honoring the

tickets or busbills of another carrier sold at such other locations.

3. discriminating against any tenant carrier in the terms or

conditions of any BTL Agreement or other agreement governing the lease

of space in a bus terminal, where the purpose or effect of such

discrimination is to (a) prohibit a tenant carrier from (i) selling its

tickets or busbills at locations, other than the Greyhound terminal,

for transportation services using that Greyhound terminal or a terminal

or facility that is competitive with such Greyhound terminal, or (ii)

honoring the tickets or busbills of another carrier sold at such other

locations, or (b) prohibit or substantially limit the tenant from

interlining any of its traffic with another carrier at another

terminal.

4. refusing to interline with any other carrier unless that carrier

agrees to interline all of its traffic in a city or area with

Greyhound, provided, however, that this paragraph shall not apply to an

agreement between Greyhound and its franchisee, operating lessee or

contractor.

(C) Nothing in this Final Judgment shall:

1. affect any provisions of defendant's existing BTL Agreements,

other than the Twenty-five (25) Mile Rule.

2. restrict Greyhound from (i) negotiating or renegotiating any

percentage or minimum rents or other terms of compensation, including

different terms of compensation for different tenants, provided that

such differences in rents or terms of compensation are not conditioned

on the tenant's use or non-use of a terminal other than the Greyhound

terminal or (ii) from requiring that a tenant provide Greyhound with

information on traffic volume using the Greyhound terminal, ticket

sales of originating traffic or similar information needed to calculate

or adjust compensation.

3. restrict Greyhound from negotiating or renegotiating any non-

compensation terms or provisions in its current or future BTL

Agreement, except as provided in paragraph B above.

4. affect Greyhound's right to grant, control or terminate access

to or usage of its terminals, including but not limited to termination

for breach of a BTL Agreement, except as provided in paragraph B above.

5. affect Greyhound's right to terminate any BTL Agreement due to a

tenant carrier's refusal to renegotiate or agree to amended terms and

conditions of a BTL Agreement, except as provided in paragraph B above.

6. except as provided in paragraphs B(3) and C(2) above, require

Greyhound to offer all tenants at a terminal identical terms of access,

including but not limited to terms of compensation.

7. affect Greyhound's obligation to comply with any federal, state

or local law, rule, regulation or administrative order pertaining to

terminal access or the interlining of traffic among carriers or affect

Greyhound's operations pursuant to any effective tariff filed with the

Interstate Commerce Commission or any successor agency, including any

Commission or agency decision ruling upon or interpreting such tariff,

or any pooling agreements while approved by the Interstate Commerce

Commission or any successor agency.

8. affect Greyhound's unilateral right to: (i) refuse to enter

into, or terminate any interline agreement with any carrier; (ii)

refuse to provide services to any carrier that has not authorized

Greyhound to furnish such services or has not agreed to compensate

[[Page 53204]]

Greyhound for such services pursuant to an agreement, or (iii)

establish passenger or package express fares, terms or conditions

relating to its transportation services.

V

Disclosure

Defendant is ordered to send, within 60 days from the date of entry

of this Final Judgment, a copy of this Final Judgment to each tenant

carrier subject to a BTL Agreement, together with a written statement

that the Twenty-five (25) Mile Rule is no longer in effect and will not

be enforced.

VI

Compliance Program

Defendant is ordered to maintain an antitrust compliance program

which shall include the following:

(A) Designating within 30 days of entry of this Final Judgment, an

Antitrust Compliance Officer with responsibility for accomplishing the

antitrust compliance program and with the purpose of achieving

compliance with this Final Judgment. The Antitrust Compliance Officer

shall, on a continuing basis, supervise the review of the current and

proposed activities of defendant to ensure that it complies with this

Final Judgment.

(B) The Antitrust Compliance Officer shall be responsible for

accomplishing the following activities:

1. distributing copies of this Final Judgment in accordance with

section V above;

2. distributing, within 60 days from the entry of this Final

Judgment, a copy of this Final Judgment to all officers and employees

with responsibility for operating or managing terminals, negotiating

BTL (or other terminal access) Agreements, overseeing compliance with

BTL (or other terminal access) Agreements, or tenant carrier relations;

3. briefing annually the officers and employees described above on

this Final Judgment.

VII

Certification

(A) Within 75 days after the entry of this Final Judgment, the

defendant shall certify to the plaintiff that it has complied with

IV(A) above, designated, an Antitrust Compliance Officer, and

distributed the Final Judgment in accordance with Sections V and VI

above.

(B) For each year of the term of this Final Judgment, the defendant

shall file with the plaintiff, on or before the anniversary date of

entry of this Final Judgment, a statement as to the fact and manner of

its compliance with the provisions of V and VI above.

VIII

Plaintiff Access

(A) To determine or secure compliance with this Final Judgment and

for no other purpose, duly authorized representatives of the plaintiff

shall, upon written request of the Assistant Attorney General in charge

of the Antitrust Division, and on reasonable notice to the defendant

made to its principal office, be permitted, subject to any legally

recognized privilege:

1. access during the defendant's normal office hours to inspect and

copy all documents in the possession or under the control of the

defendant, who may have counsel present, relating to any matters

contained in this Final Judgment; and

2. subject to the reasonable convenience of the defendant and

without restraint or interference from it, to interview officers,

employees or agents of the defendant, who may have counsel present,

regarding such matters.

(B) Upon the written request of the Assistant Attorney General in

charge of the Antitrust Division made to the defendant's principal

office, the defendant shall submit such written reports, under oath if

requested, subject to any legally recognized privilege.

(C) No information or documents obtained by the means provided in

Section VIII shall be divulged by the plaintiff to any person other

than a duly authorized representative of the Executive Branch of the

United States, except in the course of legal proceedings to which the

United States is a party, or for the purpose of securing compliance

with this Final Judgment, or as otherwise required by law.

(D) If at the time information or documents are furnished by the

defendant to plaintiff, the defendant represents and identifies in

writing the material in any such information or documents to which a

claim of protection may be asserted under Rule 26(c)(7) of the Federal

Rules of Civil Procedure, and defendant marks such material, ``subject

to claim of protection under Rule 26(c)(7) of the Federal Rules of

Civil Procedure,'' then 10 days notice shall be given by plaintiff to

defendant prior to divulging such material in any legal proceeding

(other than a grand jury proceeding) to which defendant is not a party.

IX

Further Elements of the Final Judgment

(A) This Final Judgment shall expire ten years from the date of

entry.

(B) Jurisdiction is retained by this Court for the purpose of

enabling the parties to this Final Judgment to apply to this Court at

any time for further orders and directions as may be necessary or

appropriate to carry out or construe this Final Judgment, to modify or

terminate any of its provisions, to enforce compliance, and to punish

violations of its provisions.

(C) Entry of this Final Judgment is in the public interest.

Dated ____________.

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

UNITED STATES DISTRICT JUDGE

United States District Court for the District of Columbia

United States of America, Plaintiff, vs. Greyhound Lines, Inc.

Defendant.

[Case Number: 1:95CV01852]

Judge: Royce C. Lamberth.

Date Stamp: 09/28/95.

Competitive Impact Statement

Pursuant to Section 2(b) of the Antitrust Procedures and Penalties

Act (``APPA''), 15 U.S.C. 16(b)-(h), the United States files this

Competitive Impact Statement relating to the proposed Final Judgment

submitted for entry with the consent of Greyhound Lines, Inc. in this

antitrust proceeding.

I

Nature and Purpose of the Proceeding

On September 28, 1995, the United States filed a Complaint alleging

that Greyhound Lines, Inc. (``Greyhound'') had violated Section 1 of

the Sherman Act, 15 U.S.C. 1. The Complaint challenges a provision in

Greyhound's bus terminal leases that prohibit tenant bus companies from

selling tickets for intercity bus transportation within a 25-mile

radius of Greyhound's terminals. The effect of this provision, commonly

known as the ``25-mile rule,'' has been to restrict competition in the

provision of intercity bus transportation service and in the sale of

tickets for such service.

On September 28, 1995, the United States and Greyhound filed a

Stipulation by which they consented to the entry of a proposed Final

Judgment designed to eliminate the 25-mile rule and prevent Greyhound

from using any similar restriction. Under the proposed Final Judgment,

Greyhound would be required to remove the 25-mile rule from existing

terminal leases and would be enjoined from taking actions to

[[Page 53205]]

impose similar restrictions on tenants in the future.

The United States and Greyhound have agreed that the proposed Final

Judgment may be entered after compliance with the APPA. Entry of the

proposed Final Judgment will terminate the action, except that the

Court will retain jurisdiction to construe, modify, and enforce the

Final Judgment, and to punish violations of the its provisions.

II

Description of the Alleged Violation

Greyhound is the only nationwide intercity but company providing

bus transportation services for passengers and package express.

Greyhound's total operating revenues for 1994 were approximately $616

million.

Greyhound operates approximately 200 bus terminals throughout the

United States. Many smaller bus companies operate out of Greyhound's

terminals pursuant to agreements known as Bus Terminal License

(``BTL'') agreements. Currently. Greyhound has approximately 200 BTLs

in effect with tenant bus companies in approximately 135 cities.

Under the terms of the BTLs, Greyhound acts as the tenant bus

companies' exclusive ticket agent, and also provides other services,

including baggage handling, package express handling, and maintenance

of the terminal facilities. The tenant bus companies pay rents based on

ticket sales, either in the form of a set commission on each ticket

sold or a pro rata share of the costs of operating the terminal. If a

tenant's sales fall below a certain level, it pays a minimum rental fee

specified in the BTL. The BTLs are terminable by either party on 30-

days notice.

In August of 1992, Greyhound notified its tenants that all existing

BTLs were to be terminated effective September 30, 1992, and that those

bus companies wishing to remain tenants of Greyhound would be required

to execute a new standardized BTL. Following several months of

negotiations, Greyhound and its tenants executed new BTLs, most of

which became effective in the first half of 1993.

One of the new provisions contained in the current BTL agreements

between Greyhound and its tenants is the 25-mile rule. The provision

reads as follows:

Subject to Section 1, Licensee agrees that during the term

hereof, it will use the Terminal as its major terminal in the City

of ________ for the aforesaid operations and will not without the

prior written consent of Company allow or permit any tickets or

busbills to be sold at any other place within a twenty-five (25)

mile radius of the Terminal, other than the Terminal, or honor the

tickets or busbills of any other carrier for such transportation

which are sold within the said twenty-five (25) mile radius.

Notwithstanding the foregoing, tickets or busbills of Licensee may

continue to be sold, and Licensee may honor the tickets or busbills

of other carriers which are sold, at any place within the twenty-

five (25) mile radius where they are being sold as of the date of

this Agreement. A list of such places where tickets or busbills of

Licensee are sold within the twenty-five mile radius of the Terminal

is appended to this Agreement as Appendix 3. If Licensee wishes to

change any such place of sale of its tickets or busbills to another

place within five (5) miles of such place and within the said

twenty-five (25) mile radius of the Terminal, Licensee may make such

change upon thirty (30) days written notice to Company. It is

further understood that in all of Licensee's bus schedules and

advertising pertaining to its aforesaid operations, the Terminal

shall appear as the only place in the City of ________ where tickets

or busbills are on sale.

The 25-mile rule prevents the tenant bus companies from selling bus

tickets within a 25-mile radius of the Greyhound terminal in which they

are a tenant, unless the location was grandfathered-in at the time the

BTL was negotiated. The tenant bus companies are also prohibited from

accepting bus tickets sold by any other carrier within the 25-mile

area. Thus, tenant bus companies are prohibited from selling tickets at

other bus terminals or stops, through travel agents, or by telephone

from locations within the 25-mile radius.

The rule has anticompetitive effects in two types of markets:

intercity bus service and ticket distribution services. The effects on

intercity bus service are of great concern and occur when the tenant is

an actual or potential competitor of Greyhound in the provision of

intercity bus service (either alone or, more commonly, through

interlining with another carrier) in at least some city-pairs . In

addition, the rule eliminates competition in the distribution of bus

tickets, making Greyhound the exclusive ticket agent in the 25-mile

area.

Although most cities and towns are served by only the Greyhound

terminal, in some larger metropolitan areas a second terminal exists.

Bus companies often wish to serve more than one terminal in the same

city in order to increase their opportunities to interline (exchange

passengers) with other bus companies. Interlining benefits consumers by

both increasing the number of destinations to which they have

convenient connecting service and, in some cases, by giving consumers a

choice between competing bus companies for at least part of their trip.

Because bus companies generally find it undesirable to operate out of a

terminal if originating passengers cannot purchase tickets there, the

25-mile rule effectively prevents the tenants from operating from the

second terminal. Indeed, by preventing Greyhound tenants from operating

out of multiple terminals, the 25-mile rule may inhibit establishment

of a second terminal. In addition, the 25-mile rule prevents tenant

carriers from operating from non-terminal facilities that may be

convenient for consumers, such as stops at airports, train stations, or

college campuses. The 25-mile rule thus acts to prevent Greyhound's

tenants from expanding their operations in ways that would

significantly benefit consumers.

III

Explanation of the Proposed Final Judgment

The proposed Final Judgment is designed to eliminate the 25-mile

rule from existing BTLs and to prevent future actions by the defendant

to place similar restrictions on ticket sales or interlining by tenant

bus companies. Greyhound is required to remove the 25-mile rule from

each BTL within 60 days of the entry of the Final Judgment (Section

IV(A)). Greyhound is enjoined from conditioning access to its

terminals, directly or indirectly, on an agreement not to sell tickets

outside the Greyhound terminal (Section IV(B)1), terminating or

threatening to terminate a BTL where the purpose or effect is to

prohibit outside ticket sales (Section IV(B)2), or discriminating

against a tenant carrier in the terms and conditions of terminal access

where the purpose or effect is to prohibit outside ticket sales

(Section IV(B)3). Greyhound is also enjoined from refusing to interline

with a carrier unless that carrier agrees to interline exclusively with

Greyhound (Section IV(B)4).

Aside from the prohibition of the 25-mile rule or any similar

restriction, the proposed Final Judgment does not limit Greyhound's

ability to negotiate rents and other BTL terms with its tenants and to

control terminal access (Section IV(C)). Within 60 days of entry of the

proposed Final Judgment, Greyhound must provide each tenant bus company

with a copy of the Final Judgment along with a written statement that

the 25-mile rule is no longer in effect (Section V). The proposed Final

Judgment further requires Greyhound to establish an antitrust

compliance program (Section VI) and file an annual certificate of

compliance with the

[[Page 53206]]

Government (Section VII). The plaintiff may also obtain information

from the defendant concerning possible violations of the Final Judgment

(Section VIII).

IV

Remedies Available to Potential Private Litigants

Section 4 of the Clayton Act, 15 U.S.C. 15, provides that any

person who has been injured in his business or property as a result of

conduct forbidden by the antitrust laws may bring suit in federal court

to recover three times the damages suffered, as well as costs and

reasonable attorneys fees. Entry of the proposed Final Judgment will

neither impair nor assist the bringing of any private antitrust damage

action. Under the provisions of Section 5(a) of the Clayton Act, 15

U.S.C. 16(a), the proposed Final Judgment has no prima facie effect in

any subsequent private lawsuit that may be brought.

V

Procedure Available for Modification of the Proposed Final Judgment

The United States and defendant have stipulated that the proposed

Final Judgment may be entered by the Court after compliance with the

provisions of the APPA, provided that the United States has not

withdrawn its consent. The APPA conditions entry upon the Court's

determination that the proposed Final Judgment is in the public

interest.

The APPA provides a period of at least 60 days preceding the

effective date of the proposed Final Judgment within which any person

may submit to the United States written comments regarding the proposed

Final Judgment. Any person who wishes to comment should do so within 60

days of the date of publication of this Competitive Impact Statement in

the Federal Register. The United States will evaluate the comments,

determine whether it should withdraw its consent, and respond to the

comments. The comments and the response of the United States will be

filed with the Court and published in the Federal Register.

Written comments should be submitted to: Roger W. Fones, Chief,

Transportation, Energy & Agriculture Section, Antitrust Division, U.S.

Department of Justice, Judiciary Center Building, 555 Fourth Street

NW., Rm. 9104, Washington, DC 20001.

VI

Alternative to the Proposed Final Judgment

The alternative to the proposed Final Judgment would be a full

trial of the case against Greyhound. In the view of the Department of

Justice, such a trial would involve substantial cost to the United

States and is not warranted because the proposed Final Judgment

provides relief that will remedy the violations of the Sherman Act

alleged in the Complaint.

VII

Determinative Materials and Documents

There are no materials or documents that the United States

considered to be determinative in formulating this proposed Final

Judgment. Accordingly, none are being filed with this Competitive

Impact Statement.

Dated: September 28, 1995.

Respectfully submitted,

Michael D. Billiel (D.C. Bar #394377),

Michele B. Felasco,

Attorneys, U.S. Department of Justice, Antitrust Division, 555 Fourth

Street, N.W., Washington, D.C. 20001, (202) 307-6666.

Certificate of Service

I hereby certify that I have caused a copy of the foregoing

Competitive Impact Statement to be served on counsel for defendant in

this matter in the manner set forth below:

By hand: Mark F. Horning, Esquire, Steptoe & Johnson, 1330

Connecticut Ave., N.W., Washington, D.C. 20036-1795, for defendant

Greyhound Lines, Inc.

Dated: September 28, 1995.

Michael D. Billiel,

Antitrust Division, U.S. Department of Justice, 555 Fourth Street,

N.W., Washington, D.C. 20001, (202) 307-6666.

[FR Doc. 95-25289 Filed 10-11-95; 8:45 am]

BILLING CODE 4410-01-M