24544 Federal Register / Vol. 63, No. 85 / Monday, May 4, 1998 / Notices

1The number of bits generally correlates with the

amount of data that a microprocessor can process

during one clock cycle. Intel’s current Pentium

microprocessors have a 32-bit architecture (known

as IA–32), while Digital’s alpha chip has a 64-bit

architecture.

2Windows and Windows NT are operating

systems. Operating systems are a type of software

that acts as an intermediary between applications

software and the microprocessor. An operating

system runs in ‘‘native’’ mode when it is

specifically written to interact optimally with the

particular microprocessor architecture. Microsoft,

the developer of Windows NT, today supports only

two microprocessor architectures—Intel’s and

Digital’s—to run Windows NT in native mode.

Other microprocessor architectures today must use

translation software in order to run Windows NT,

significantly reducing performance and speed.

forwarders pursuant to section 19 of the

Shipping Act of 1984 (46 U.S.C. app.

1718 and 46 CFR Part 510).

Persons knowing of any reason why

any of the following applicants should

not receive a license are requested to

contact the Office of Freight Forwarders,

Federal Maritime Commission,

Washington, DC 20573.

International Transportation

Consultants, Ltd., d/b/a I.T.C., Ltd.,

1551–53 Carmen Drive, Elk Grove

Village, IL 60007

Officers: Wladimir Leonartowicz,

President, Marc Leonartowicz, Vice

President

Dated: April 28, 1998.

Joseph C. Polking,

Secretary.

[FR Doc. 98–11680 Filed 5–1–98; 8:45 am]

BILLING CODE 6730–01–M

FEDERAL RETIREMENT THRIFT

INVESTMENT BOARD

Sunshine Act Meeting

TIME AND DATE: 9:00 a.m. (EDT), May 11,

1998.

PLACE: 4th Floor, Conference Room,

1250 H Street, N.W., Washington, D.C.

STATUS: Open.

MATTERS TO BE CONSIDERED:

1. National Finance Center record

keeping.

2. Congressional/agency/participant

liaison.

3. Benefits administration.

4. Investments.

5. Participant communications.

6. Approval of the minutes of the

April 13, 1998, Board member meeting.

7. Thrift Savings Plan activity report

by the Executive Director.

8. Approval of the update of the FY

1998 budget and FY 1999 estimates.

9. Investment policy review.

10. Review of KPMG Peat Marwick

audit report: ‘‘Pension and Welfare

Benefits Administration Review of

Capacity Planning and Performance

Management of the Thrift Savings Plan

at the United States Department of

Agriculture, National Finance Center.’’

11. Status of audit recommendations.

CONTACT PERSON FOR MORE INFORMATION:

Thomas J. Trabucco, Director, Office of

External Affairs, (202) 942–1640.

Dated: April 29, 1998.

Roger W. Mehle,

Executive Director, Federal Retirement Thrift

Investment Board.

[FR Doc. 98–11819 Filed 4–29–98; 4:56 pm]

BILLING CODE 6760–01–M

FEDERAL TRADE COMMISSION

[File No. 981–0040]

Digital Equipment Corporation;

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 of 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 July 6, 1998.

ADDRESSES: Comments should be

directed to: FTC/Office of the Secretary,

Room 159, 6th St. and Pa. Ave., N.W.,

Washington, D.C. 20580.

FOR FURTHER INFORMATION CONTACT:

William Baer or Willard Tom, FTC/H–

374, Washington, D.C. 20580 (202) 326–

2932 or 326–2786.

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 sixty (60) 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 April 23, 1998), on the

World Wide Web, at ‘‘http://

www.ftc.gov/os/actions97.htm.’’ A

paper copy can be obtained from the

FTC Public Reference Room, Room H–

130, Sixth Street and Pennsylvania

Avenue, N.W., Washington, D.C. 20580,

either in person or by calling (202) 326–

3627. Public comment is invited. 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 To Aid Public Comment

I. Introduction

The Federal Trade Commission

(‘‘Commission’’) has accepted from

Digital Equipment Corporation

(‘‘Digital’’) an Agreement Containing

Consent Order (‘‘Proposed Consent

Order’’). The Proposed Consent Order is

designed to remedy anticompetitive

effects likely to occur in three product

markets as a result of the acquisition by

Intel Corporation (‘‘Intel’’) of certain

assets of Digital. The Order requires that

Digital License its Alpha microprocessor

technology to two Commissionapproved companies to ensure that

there are independent suppliers and

developers of Alpha. The Order ensures

that Intel will not have exclusive control

over the technology, and that Alpha will

remain competitive.

II. Description of the Parties and the

Transaction

Digital is a Massachusetts corporation

headquartered in Maryland,

Massachusetts, with sales of

approximately $13 billion and net

income of over $140 million for the

fiscal year ended June 28, 1997. Digital

manufactures and sells computer

systems, and develops, manufactures,

and sells microprocessors based on its

proprietary 64-bit 1 Alpha architecture.

The Alpha microprocessor is widely

regarded as among the highest

performing general purpose

microprocessors available and is the

only non-Intel microprocessor

architecture that can run the Windows

NT operating system in ‘‘native’’ mode.2

Digital is the largest consumer of Alpha

chips, which it uses in its computer

systems.

Intel Corporation (‘‘Intel’’), a Delaware

corporation headquartered in Santa

Clara, California, is the world’s leading

semiconductor manufacturer. Intel

reported 1996 sales of approximately

$20.8 billion and net income of more

than $5 billion. Intel supplies a broad
Federal Register / Vol. 63, No. 85 / Monday, May 4, 1998 / Notices 24545

3‘‘X–86 architecture’’ generally refers to the

original line of Intel microprocessor products for

personal computers and includes successive

generations such as the 8096, 286, 386, 486 and the

Pentium family of chips. 4See fn. 2.

line of semiconductor devices used as

computer system components,

including x86-compatible

microprocessors 3 such as the Pentium

line, which are used primarily in

conjunction with Microsoft’s Windows

and Windows NT operating systems.

Intel has been working with other

companies to develop a 64-bit

microprocessor (currently known by the

project name Merced) with a new 64-hit

architecture (known as IA–64), which is

intended to extend Intel’s current x86

architecture and compete with Digital’s

Alpha architecture.

The proposed transaction resolves

three pending lawsuits between Digital

and Intel relating to microprocessor

intellectual property and technology

rights. Digital initiated that litigation in

May 1997, claiming the Intel infringed

ten Digital patents by making and

selling Intel Pentium chips. Intel

countersued, claiming, among other

things, that Digital is infringing nine

Intel patents by making and selling

Alpha microprocessors.

On October 26, 1997, the parties

agreed to settle the litigation and grant

each other broad patent cross-licenses.

Intel would also buy Digital’s

microprocessor production facilities

(such a facility is known in industry

parlance as a ‘‘fab’’) for net book value

(approximately $650 million). In

addition, Intel agreed to produce Alpha

microprocessors for supply exclusively

to Digital. Digital agreed to endorse

publicly these IA–64 architecture and

design some Digital computer systems

based on Intel 64-bit microprocessors.

Digital will retain the intellectual

property rights and design assets for

Alpha, including the design engineers

who conduct research and development

for the Alpha architecture.

III. Competitive Concerns

A. Relevant Markets

The draft Complaint alleges three

relevant markets: (1) The manufacture

and sale of high-performance, generalpurpose microprocessors that are

capable of running the Windows NT

operating system in native mode; (2) the

manufacture and sale of all generalpurpose microprocessors and (3) the

design and development of future

generations of high performance,

general-purpose microprocessors.

The Complaint alleges that

microprocessors designed to run the

Windows NT Operating system and its

complementary application programs

constitute a relevant antitrust product

market. The demand for

microprocessors is determined

indirectly by the demand for operating

systems, which is determined in part by

the software applications that run on

those systems. Applications are

designed for specific operating systems;

operating systems can optimally run

application programs only when the

operating system is written for the

microprocessor architecture (so that the

microprocessor runs native on that

operating (system). Consumers cannot

readily switch between computer

systems that use different

microprocessor architectures, because in

most cases such a switch also requires

changing the operating system and

application programs, an expensive

proposition and one that may not yield

the same level of functionality enjoyed

by consumers on their former systems.

Windows NT is currently written in

two versions, so that only the Alpha

microprocessor and the Intel-based

microprocessors can run it in native

mode.4 Windows NT will also be

compatible with Merced, Intel’s 64-bit

chip, which will not be commercially

available until 1999. Thus, consumers

using software optimized for use with

Windows NT must choose between

Intel-based and Alpha-based systems.

Thus, if the price of Alpha and high-end

Intel microprocessors were to increase

by 5 percent, consumers using Windows

NT would not readily switch to

computer systems built with alternative

microprocessors.

The Complaint also alleges that a

second relevant product market

includes all general-purpose

microprocessors, a category that

includes devices based on the Intel and

Alpha architectures, as well as

microprocessors based on other rival

architectures such as those developed

by Hewlett-Packard (PA–RISC), Sun

Microsystems (SPARC), IBM (PowerPC),

and Silicon Graphics (MIPS). Because

only Alpha and Intel microprocessors

can optimally run Windows NT,

however, these two microprocessors are

the closest substitutes in this broader,

differentiated product market.

Finally, the Complaint alleges that the

transaction will reduce competition in

the innovation market for the design of

microprocessors. Intel and Digital are

two of a very few competitors

developing next-generation, highperformance microprocessors. Computer

makers choose microprocessors based,

in part, on the ‘‘roadmap’’ provided by

each microprocessor manufacturer—that

is, the manufacturer’s projection of

future expected increases in

performance and functionality for

successive generations of

microprocessors based on the same

architecture. Roadmaps therefore

provide an essential element of

microprocessor competition. Intel and

Digital compete for sales to computer

manufacturers, based on their

roadmaps, and they use each other’s

roadmaps as benchmarks for developing

next-generation products to leapfrog the

performance of the rival company’s

chips.

B. Barriers to Entry

The Complaint alleges there are

significant barriers to entry in the

market, including incurring large sunk

costs to build a fab and design a

microprocessor, overcoming the

network externalities and Intel’s

installed base, obtaining Microsoft

support to obtain Windows NTcompatibility, building a reputation as a

reliable microprocessor manufacturer

and innovator.

Building a new microprocessor

facility requires the expenditure of

substantial fixed and sunk costs and

takes many years. A new entrant must

also design the microprocessor, an

expensive and lengthy process.

Most important, a successful entrant

would need to convince computer

system manufacturers to design their

systems around the new

microprocessor. Entrants, however, face

a significant ‘‘Catch-22’’ in this

endeavor because of ‘‘network

externalities.’’ Externalities exist where

consumers place more value on a

particular technology (microprocessor,

operating system, peripherals,

applications, etc.) that is more widely

adopted than other technologies.

Software developers and computer

system manufacturers are unwilling to

support a new microprocessor

technology unless they first see that it

enjoys consumer interest. Because of

these network externalities and

reputational effects, however,

consumers are unwilling to switch to a

new microprocessor technology unless

they first see that it has compatible

operating systems, software, and

peripherals. In this environment,

consumer and industry expectations

about the degree to which a

manufacturer will be able to get network

externalities and reputational effects

working for it in the near future are

critical.

The importance of these expectations

is illustrated by Intel’s recent marketing

efforts on behalf of the Merced, its new

64-bit microprocessor. Even though
24546 Federal Register / Vol. 63, No. 85 / Monday, May 4, 1998 / Notices

5Merchant market means sales of separate

microprocessor chips to computer system

manufacturers, who then use them as a component

in their own computer systems.

6As explained more fully below, as part of this

consent agreement, Digital will be licensing Alpha

to Samsung, a company that plans to sell the Alpha

chip in the merchant market through a U.S.

subsidiary.

Merced has yet to be tested and will not

be available for more than a year, Intel

has already successfully obtained

commitments from a large share of the

software vendors and computer system

manufacturers to write software and

build computers for it.

C. Competitive Effects

Intel has market power in both

relevant microprocessor product

markets. Intel accounts for nearly 90

percent of dollar sales and nearly 85

percent of unit sales of microprocessors

for Windows NT and for nearly 90

percent of dollar sales and 80 percent of

unit sales of general-purpose

microprocessors. No firm other than

Intel accounts for more than 4 percent

of dollar sales of microprocessors or for

more than 10 percent of unit sales of

microprocessors. Finally, the

competitive significance of other highperformance microprocessors—such as

Hewlett-Packard’s PA–RISC, Sun

Microsystems’ SPARC, PowerPC from

the Motorola/IBM/Apple venture, and

Silicon Graphics’ MIPS

microprocessors—has been declining.

The transaction also threatens to

increase concentration significantly in

the relevant innovation market. Digital

and Intel are two of the most significant

innovation competitors in the design

and development of high-performance

microprocessors. Even with its

comparatively small share of the

relevant markets, the Alpha architecture

(because of Alpha’s superior processing

performance) represents the most

significant threat to Intel’s continued

market dominance. Intel’s documents

refer repeatedly to the competitive

threat posed by Alpha, which is

acknowledged by many as possibly the

best performing and fastest

microprocessor in the world. Innovation

and actual competition between the two

companies is likely to increase in the

future because of the growing popularity

of Microsoft’s Windows NT operating

system, which currently supports only

Digital’s Alpha and Intel’s advanced

microprocessors. As the demand for and

functionality of Windows NT grow, the

competition between the Alpha and

Intel architecture is likely to intensify.

On these facts, it is clear that an

acquisition of Digital by Intel would

substantially lessen competition.

Although the transaction at issue here

does not involve an outright acquisition

of Alpha technology, it nevertheless

threatens competition in the relevant

markets. Under the terms of the

settlement, Intel will acquire Digital’s

Alpha fabrication plant (known as Fab

6) and will produce Alpha chips for

Digital. Digital will retain its Alpha

intellectual property and design team

and is, therefore, only receiving

‘‘foundry’’ services (that is, a supply

agreement where one company

manufactures the product for another)

from Intel. The parties will also end the

patent litigation and sign a patent crosslicense agreement.

The proposed transaction has positive

implications for the future of Digital’s

Alpha systems. The supply agreement

frees Digital from operating a plant that

it was not able to utilize efficiently.

Because Intel manufactures a vast line

of semiconductor products, it can utilize

the plant more efficiently than Digital.

As a result, overall manufacturing costs

will go down and, under the DigitalIntel agreement, those cost reductions

will be passed on to Digital. Under the

agreement, Digital will also be able to

bring the next generation of Alphas—

based on an improved .18 micron

process technology—to market earlier

than it would have absent the

transaction.

Digital’s move to this ‘‘fabless’’

business model of operation is not

unprecedented. Other successful

companies—like Sun Microsystems, Inc.

and Silicon Graphics—have designed

high performance microprocessors

while relying on third-party foundries

for manufacturing. None of the other

fabless microprocessor companies,

however, placed manufacturing in the

hands of such a dominant competitor.

Because of this unique characteristic,

the proposed transaction creates the

opportunity for Intel to slow down or

otherwise impair the supply of Alpha

microprocessors, harming competition

in the relevant markets. In particular,

the transaction presents a risk that Intel

will not provide the necessary level of

coordination between the design and

manufacturing processes, and that Intel

may take other steps to reduce quality

and slow the supply of Alpha

microprocessors to Digital. Every

foundry arrangement requires design

engineers and manufacturing process

engineers to coordinate their efforts. The

development of a microprocessor

involves conforming that design to the

process technology and vice-versa. The

Digital-Intel settlement separates these

functions and provides no incentive for

Intel to ‘‘tweak’’ its own processes to

conform to Digital’s products.

Furthermore, the transaction as

proposed threatens the continued

viability of Digital’s sales of Alpha to

the ‘‘merchant market.’’ 5 As part of this

transaction, Digital is selling off most of

its semiconductor business to Intel and

thus will have no economic need for a

marketing staff, which includes people

who market Alpha to other computer

system manufacturers. Without a

marketing staff to service and pursue the

merchant market, the loss of

competition would be significant.6

Computer system manufacturers using

Alpha microprocessors have pioneered

the opening of new market segment for

Alpha-based systems, such as media

graphics. With the expected growth of

Windows NT, Alpha and Intel should go

head-to-head in competition in these

market segments for these systems. The

uncertainty created by the proposed

transaction, had it not been addressed

by the proposed consent, could have

reduced competition between Intel and

Alpha processors, resulting in higher

prices, reduced consumer choice, and

lower rates of innovation.

The Complaint concludes that, unless

remedied, the transaction is likely to

create uncertainty regarding the future

competitive viability of Alpha, thereby

maintaining and enhancing Intel’s

market power, which could result in

increased prices and reduced quality

and innovation in each of the relevant

markets for the following reasons: (1) By

making it less likely that Digital would

maintain the sales force to continue

‘‘merchant market’’ sales of Alpha

microprocessors and other products to

other computer system manufacturers, it

would reduce competition between Intel

and Digital for such sales; and (2)

putting Digital’s supply of Alpha solely

in the hands of Intel would give Intel

the opportunity to delay production of

Alpha microprocessors, impede the

development of new generations of

Alpha microprocessors, and otherwise

undermine the competitiveness of

Alpha. In these ways, according to the

Complaint, the consummation of the

proposed transaction, without any

changes, would violate Section 5 of the

Federal Trade Commission Act, as

amended, 15 U.S.C. 45, and Section 7 of

the Clayton Act, as amended, 15 U.S.C.

18.

IV. The Proposed Consent Order

The Commission has entered into an

agreement containing a Proposed

Consent Order with Digital in settlement

of the draft Complaint. The Proposed

Consent Order is designed to preserve

Alpha’s future viability by ensuring

alternative sources for production,
Federal Register / Vol. 63, No. 85 / Monday, May 4, 1998 / Notices 24547

7The Proposed Consent Order also includes

provisions for an ‘‘Interim Trustee’’ (i.e., an auditor)

and a licensing trustee. The Interim Trustee

provision assures early assessment and monitoring

of Digital’s agreements with the licensees and

continuing monitoring and reporting to the

Commission of how the provisions are working.

The licensing trustee provision is triggered if the

parties to a licensing agreement fail to agree within

the requisite time.

8An architectural integrity provision in the Order

preserves backward compatibility for existing

applications written to exploit the architecture, and

to make designing easier for applications

developers that have not yet ported applications to

Alpha. If Digital fails to innovate and improve the

performance of the Alpha architecture, however,

the Order allows AMD to modify the base

architecture without Digital approval.

marketing, and development of Alpha

products. The Proposed Consent Order

requires Digital to enter into or to

continue certain licensing arrangements

and alliances with Advanced Micro

Devices, Inc. (‘‘AMD’’), Samsung

Electronics Co., Ltd. (‘‘Samsung’’), or

some other Commission-approved

licensee, and to be begin the process of

certifying International Business

Machines, Inc. (‘‘IBM’’), or some other

Commission-approved company, to

become an Alpha foundry. The purpose

of these provisions is to establish two

licensees and another foundry as

providers and developers of Alpha

devices, independent of Intel.

The Proposed Consent Order binds

Digital to comply with the terms of

agreements it already has entered into

with Samsung. Under those agreements,

Samsung will obtain an architectural

license and technical support.

Furthermore, Digital will grant to

Samsung a non-exclusive

AlphaPowered trademark license and

the assistance and support necessary to

enable Samsung to enter rapidly and

expand the merchant market segment

for Alpha products.7 Under the current

version of the Samsung-Digital

agreement, Samsung will be creating a

U.S. subsidiary, to be known as the

Alpha Volume Company, that plans to

market Alpha chips to the merchant

market segment. Furthermore, Digital

has committed to purchase substantial

volumes of its Alpha products needs at

a competitive price from Samsung, thus

reducing its reliance on Intel.

The Proposed Consent Order also

requires Digital to enter into a broad

license with AMD, or a Commissionapproved licensee, that includes a

license to the Alpha architecture and

software tools that enable AMD to

develop microprocessors compatible

with the Alpha architecture. Digital

must provide technical and engineering

support until AMD is capable of

independently developing and

producing products based on the Alpha

architecture, but in no event for more

than two years.

The licenses with AMD and Samsung

(or two other Commission-approved

companies) are architectural licenses,

meaning that the license is to the Alpha

architecture, as defined by convention

in Digital’s official reference manual.

Under such license, the licensee is free

to create its own implementations and

derivative works—that is, to design

original chips around the architecture—

with the one caveat that it maintain

backward compatibility with the

existing Alpha architecture.8 In this

way, a licensee will have every

incentive to develop the merchant

market aggressively because it will have

the ability to create Alpha-derivative

innovations that can give it profitable

‘‘design wins’’—that is, agreements with

computer system manufacturers by

which the computer system

manufacturers will design a computer

line around the licensee’s chip. These

architectural licenses also provide

assurance to customers who commit to

the Alpha architecture because the

licenses provide independent sources of

supply and innovation for these

microprocessors.

The Proposed Consent Order also

requires Digital to enter into an

agreement, subject to Commission

approval, with IBM or some other

Commission-approved company to

evaluate that company as a potential

foundry for Alpha parts and to inform

that foundry partner of the steps

necessary to become a qualified supplier

of Alpha products. Submission of that

agreement is required within six months

of Commission approval of the Proposed

Consent Order. Alternatively, the

Proposed Consent Order permits Digital

to demonstrate why such an agreement

is unnecessary.

Samsung is a leading supplier of

DRAM technology, is considered to

have excellent manufacturing quality,

and will receive marketing assistance

from Digital. Samsung is already in the

merchant market and the Order should

empower Sumsung to further its

marketing efforts in this important

segment. AMD is the leading challenger

to Intel for x86-compatible

microprocessors and already a major

merchant market supplier, with

excellent design capabilities. Though

AMD does not yet produce Alpha chips,

it should have every ability to do so.

AMD is a major supplier of

microprocessors and should have

significant incentives to develop an

Alpha-based business because it does

not otherwise have a 64-bit architecture

capable of challenging the upcoming

Intel IA–64 architecture. IBM is an

established high-performance

microprocessor foundry, likely to be

capable of producing Alpha products.

All three of these companies, or other

licensees, help to ensure adequate and

independent supplies of Alpha

microprocessors.

V. Opportunity for Public Comment

The Proposed Consent Order has been

placed on the public record for sixty

(60) days for receipt of comments by

interested persons about both the

appropriateness of the relief provided

herein as well as the suitability of

Samsung, AMD, and IBM as licensees

who can ensure alternative sources for

the manufacture, marketing, and

development of Alpha products.

Comments received during this period

will become part of the public record.

After sixty days, the Commission will

again review the Proposed Consent

Order and the comments received and

will decide whether it should withdraw

from the Proposed Consent Order or

make it final.

By accepting the Proposed Consent

Order 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 Order, including the proposed

licenses and alliances, to help the

Commission determine whether to make

final the Proposed Consent Order

contained in the agreement. This

analysis is not intended to constitute an

official interpretation of the Proposed

Consent Order, nor is it intended to

modify the terms of the Proposed

Consent Order in any way.

By direction of the Commission.

Donald S. Clark,

Secretary.

[FR Doc. 98–11798 Filed 5–1–98; 8:45 am]

BILLING CODE 6750–01–M

GENERAL SERVICES

ADMINISTRATION

Notice of Availability (NOA); Record of

Decision (ROD); Immigration and

Naturalization Service (INS) Lease

Construction and Consolidation, Dade

County, Florida

April 23, 1998.

This is the Record of Decision (ROD)

for the GSA Proposed Action, which is

to lease a building to be constructed at

9300–9499 NW 41st Street in Western

Dade County, Florida. This building

would consolidate the INS District