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[Federal Register Volume 86, Number 169 (Friday, September 3, 2021)]
[Notices]
[Pages 49563-49567]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-19097]

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DEPARTMENT OF JUSTICE

Antitrust Division

United States v. Zen-Noh Grain Corporation, et al.; Response to 
Public Comments

    Pursuant to the Antitrust Procedures and Penalties Act, 15 U.S.C. 
16(b)-(h), the United States hereby publishes below the Response to 
Public Comments on the Proposed Final in United States v. Zen-Noh Grain 
Corporation, et al., Civil Action No. 1:21-cv-01482-RJL, which was 
filed in the United States District Court for the District of Columbia 
on August 30, 2021, together with a copy of the two comments received 
by the United States.
    A copy of the comments and the United States' response to the 
comments is available at https://www.justice.gov/atr/case/us-v-zen-noh-grain-corp-and-bunge-north-america-inc. Copies of the comments and the 
United States' response are available for inspection at the Office of 
the Clerk of the United States District Court for the District of 
Columbia. Copies of these materials may also be obtained from the 
Antitrust Division upon request and payment of the copying fee set by 
Department of Justice regulations.

Suzanne Morris,
Chief, Premerger and Division Statistics, Antitrust Division.

United States District Court for the District of Columbia

    United States of America, Plaintiff, v. Zen-Noh Grain Corp., and 
Bunge North America, Inc., Defendants.

Civil Action No.:1:21-cv-01482 (RJL)

Response of Plaintiff United States to Public Comments on the Proposed 
Final Judgment

    Pursuant to the requirements of the Antitrust Procedures and 
Penalties Act (the ``APPA'' or ``Tunney Act''), 15 U.S.C. 16, the 
United States hereby responds to the two public comments received 
regarding the proposed Final Judgment in this case. After careful 
consideration of the submitted comments, the United States continues to 
believe that the divestiture required by the proposed Final Judgment 
provides an effective and appropriate remedy for the antitrust 
violation alleged in the Complaint and is therefore in the public 
interest. The United States will move the Court for entry of the 
proposed Final Judgment after the public comments and this response 
have been published as required by 15 U.S.C. 16(d).

[[Page 49564]]

I. Procedural History

    On April 21, 2020, Zen-Noh Grain Corp. (``ZGC'') agreed to acquire 
35 operating and 13 idled U.S. grain elevators from Bunge North 
America, Inc. (``Bunge'') (``collectively, ``Defendants'') for 
approximately $300 million (``the Transaction''). The United States 
filed a civil antitrust Complaint on June 1, 2021, seeking to enjoin 
the proposed Transaction. The Complaint alleges that the likely effect 
of the Transaction would be to substantially lessen competition for 
purchases of corn and soybeans in nine geographic areas of the United 
States in violation of Section 7 of the Clayton Act, 15 U.S.C. 18. See 
Dkt. No.1.
    At the same time the Complaint was filed, the United States filed a 
proposed Final Judgment and an Asset Preservation and Hold Separate 
Stipulation and Order (``Stipulation and Order'') in which the United 
States and Defendants consent to entry of the proposed Final Judgment 
after compliance with the requirements of the APPA. See Dkt. Nos. 2-2, 
2-1. The proposed Final Judgment requires the Defendants to divest 
certain grain elevators and related assets of Bunge or ZGC affiliate 
CGB Enterprises, Inc. (``the Divestiture Assets'') to Viserion Grain 
LLC and Viserion International Holdco LLC (``Viserion''), or to another 
acquirer or acquirers acceptable to the United States, within 30 
calendar days after entry of the Stipulation and Order.
    Pursuant to the APPA's requirements, on June 1, 2021, the United 
States also filed a Competitive Impact Statement describing the 
transaction and the proposed Final Judgment. See Dkt. No. 3. On June 8, 
2021, the United States published the Complaint, proposed Final 
Judgment, and Competitive Impact Statement in the Federal Register, see 
86 FR 30479 (June 8, 2021), and caused notice regarding the same, 
together with directions for the submission of written comments 
relating to the proposed Final Judgment, to be published in The 
Washington Post and St. Louis Post-Dispatch, from June 4, 2021, through 
June 10, 2021. On July 1, 2021, the Court entered the Stipulation and 
Order. See Dkt. No. 14. On July 7, 2021, Defendant ZGC effectuated the 
divestiture contemplated by the proposed Final Judgment by selling the 
prescribed assets to Viserion. The 60-day period for public comment 
ended on August, 9, 2021. The United States received two comments, 
attached as Exhibits A and B.

II. The Complaint and the Amended Proposed Final Judgment

    The Complaint alleges that ZGC's proposed acquisition of certain 
grain elevator assets from Bunge would likely eliminate competition 
between the Defendants to purchase grain from farmers in numerous 
markets along the Mississippi River and its tributaries. In particular, 
the Complaint alleges that in nine geographic areas, a Bunge river 
elevator and a nearby ZGC (or ZGC affiliate CGB) elevator represent two 
of only a handful of grain purchasing alternatives for area farmers. In 
those nine geographic areas, ZGC and Bunge currently compete 
aggressively to win farmers' business by offering better prices and 
more attractive amenities such as faster grain drop-off services and 
better grain grading. Unless remedied, the Transaction will eliminate 
competition between ZGC and Bunge in those locations in violation of 
Section 7 of the Clayton Act, 15 U.S.C. 18.
    The proposed Final Judgment is designed to remedy the likely harm 
to competition alleged in the Complaint by requiring a divestiture that 
will establish an independent, economically viable competitor for the 
purchase of corn and soybeans in the nine affected geographic markets. 
The proposed Final Judgment requires the Defendants to divest nine 
elevators within 30 days after the entry of the Stipulation by the 
Court to Viserion or another acquirer or acquirers approved by the 
United States. In each of those nine geographic markets, a Bunge 
elevator competes head to head with one or more ZGC or CGB elevators.
    The Divestiture Assets include the real property, buildings, 
facilities, and other structures associated with the nine grain 
elevators. The Divestiture Assets also encompass all existing grain 
inventories at the elevators, and all contracts and other agreements 
that relate exclusively to the elevators that will be divested.
    The Divestiture Assets must be divested in such a way as to satisfy 
the United States in its sole discretion that the assets can and will 
be operated by the purchaser as a viable, ongoing business that can 
compete effectively in the market for the purchase of corn and the 
market for the purchase of soybeans. The Defendants proposed Viserion 
as the acquirer, and, after rigorous evaluation, the United States 
approved Viserion as the divestiture buyer.
    The proposed Final Judgment allows the acquirer, at its option, to 
enter into a transition services agreement with Defendants for a period 
of up to six months. As explained in the Competitive Impact Statement, 
the transition services covered by the proposed Final Judgment are 
those that might reasonably be necessary to ensure that an acquirer or 
acquirers can readily and promptly use the assets to compete in the 
relevant markets. See Dkt. No. 3 at 10 at 12.

III. Standard of Judicial Review

    The Clayton Act, as amended by the APPA, requires that proposed 
consent judgments in antitrust cases brought by the United States be 
subject to a 60-day comment period, after which the Court shall 
determine whether entry of the proposed Final Judgment ``is in the 
public interest.'' 15 U.S.C. 16(e)(1). In making that determination, 
the Court, in accordance with the statute as amended in 2004, is 
required to consider:

    (A) The competitive impact of such judgment, including 
termination of alleged violations, provisions for enforcement and 
modification, duration of relief sought, anticipated effects of 
alternative remedies actually considered, whether its terms are 
ambiguous, and any other competitive considerations bearing upon the 
adequacy of such judgment that the court deems necessary to a 
determination of whether the consent judgment is in the public 
interest; and
    (B) the impact of entry of such judgment upon competition in the 
relevant market or markets, upon the public generally and 
individuals alleging specific injury from the violations set forth 
in the complaint including consideration of the public benefit, if 
any, to be derived from a determination of the issues at trial.

15 U.S.C. 16(e)(1)(A) & (B). In considering these statutory factors, 
the Court's inquiry is necessarily a limited one as the government is 
entitled to ``broad discretion to settle with the defendant within the 
reaches of the public interest.'' United States v. Microsoft Corp., 56 
F.3d 1448, 1461 (D.C. Cir. 1995); United States v. U.S. Airways Grp., 
Inc., 38 F. Supp. 3d 69, 75 (D.D.C. 2014) (explaining that the 
``court's inquiry is limited'' in APPA settlements); United States v. 
InBev N.V./S.A., No. 08-1965 (JR), 2009 U.S. Dist. LEXIS 84787, at *3 
(D.D.C. Aug. 11, 2009) (noting that a court's review of a consent 
judgment is limited and only inquires ``into whether the government's 
determination that the proposed remedies will cure the antitrust 
violations alleged in the complaint was reasonable, and whether the 
mechanisms to enforce the final judgment are clear and manageable'').
    Under the APPA, a court considers, among other things, the 
relationship between the remedy secured and the specific allegations in 
the government's

[[Page 49565]]

complaint, whether the proposed Final Judgment is sufficiently clear, 
whether its enforcement mechanisms are sufficient, and whether it may 
positively harm third parties. See Microsoft, 56 F.3d at 1458-62. With 
respect to the adequacy of the relief secured by the proposed Final 
Judgment, a court may not ``make de novo determination of facts and 
issues.'' United States v. W. Elec. Co., 993 F.2d 1572, 1577 (D.C. Cir. 
1993) (quotation marks omitted); see also Microsoft, 56 F.3d at 1460-
62; United States v. Alcoa, Inc., 152 F. Supp. 2d 37, 40 (D.D.C. 2001); 
United States v. Enova Corp., 107 F. Supp. 2d 10, 16 (D.D.C. 2000); 
InBev, 2009 U.S. Dist. LEXIS 84787, at *3. Instead, ``[t]he balancing 
of competing social and political interests affected by a proposed 
antitrust consent decree must be left, in the first instance, to the 
discretion of the Attorney General.'' W. Elec. Co., 993 F.2d at 1577 
(quotation marks omitted).
    ``The court should bear in mind the flexibility of the public 
interest inquiry: the court's function is not to determine whether the 
resulting array of rights and liabilities is one that will best serve 
society, but only to confirm that the resulting settlement is within 
the reaches of the public interest.'' Microsoft, 56 F.3d at 1460 
(quotation marks omitted); see also United States v. Deutsche Telekom 
AG, No. 19-2232 (TJK), 2020 WL 1873555, at *7 (D.D.C. Apr. 14, 2020). 
More demanding requirements would ``have enormous practical 
consequences for the government's ability to negotiate future 
settlements,'' contrary to congressional intent. Microsoft, 56 F.3d at 
1456. ``The Tunney Act was not intended to create a disincentive to the 
use of the consent decree.'' Id.
    The United States' predictions about the efficacy of the remedy are 
to be afforded deference by the Court. See, e.g., Microsoft, 56 F.3d at 
1461 (recognizing courts should give ``due respect to the Justice 
Department's . . . view of the nature of its case''); United States v. 
Iron Mountain, Inc., 217 F. Supp. 3d 146, 152-53 (D.D.C. 2016) (``In 
evaluating objections to settlement agreements under the Tunney Act, a 
court must be mindful that [t]he government need not prove that the 
settlements will perfectly remedy the alleged antitrust harms[;] it 
need only provide a factual basis for concluding that the settlements 
are reasonably adequate remedies for the alleged harms.'') (internal 
citations omitted); United States v. Republic Servs., Inc., 723 F. 
Supp. 2d 157, 160 (D.D.C. 2010) (noting ``the deferential review to 
which the government's proposed remedy is accorded''); United States v. 
Archer-Daniels-Midland Co., 272 F. Supp. 2d 1, 6 (D.D.C. 2003) (``A 
district court must accord due respect to the government's prediction 
as to the effect of proposed remedies, its perception of the market 
structure, and its view of the nature of the case.''). The ultimate 
question is whether ``the remedies [obtained by the Final Judgment are] 
so inconsonant with the allegations charged as to fall outside of the 
`reaches of the public interest.''' Microsoft, 56 F.3d at 1461 (quoting 
W. Elec. Co., 900 F.2d at 309).
    Moreover, the Court's role under the APPA is limited to reviewing 
the remedy in relationship to the violations that the United States has 
alleged in its complaint, and does not authorize the Court to 
``construct [its] own hypothetical case and then evaluate the decree 
against that case.'' Microsoft, 56 F.3d at 1459; see also U.S. Airways, 
38 F. Supp. 3d at 75 (noting that the court must simply determine 
whether there is a factual foundation for the government's decisions 
such that its conclusions regarding the proposed settlements are 
reasonable); InBev, 2009 U.S. Dist. LEXIS 84787, at *20 (``[T]he 
`public interest' is not to be measured by comparing the violations 
alleged in the complaint against those the court believes could have, 
or even should have, been alleged.''). Because the ``court's authority 
to review the decree depends entirely on the government's exercising 
its prosecutorial discretion by bringing a case in the first place,'' 
it follows that ``the court is only authorized to review the decree 
itself,'' and not to ``effectively redraft the complaint'' to inquire 
into other matters that the United States did not pursue. Microsoft, 56 
F.3d at 1459-60.
    In its 2004 amendments to the APPA, Congress made clear its intent 
to preserve the practical benefits of using consent judgments proposed 
by the United States in antitrust enforcement, Public Law 108-237, 221, 
and added the unambiguous instruction that ``[n]othing in this section 
shall be construed to require the court to conduct an evidentiary 
hearing or to require the court to permit anyone to intervene.'' 15 
U.S.C. 16(e)(2); see also U.S. Airways, 38 F. Supp. 3d at 76 
(indicating that a court is not required to hold an evidentiary hearing 
or to permit intervenors as part of its review under the APPA). This 
language explicitly wrote into the statute what Congress intended when 
it first enacted the APPA in 1974. As Senator Tunney explained: ``[t]he 
court is nowhere compelled to go to trial or to engage in extended 
proceedings which might have the effect of vitiating the benefits of 
prompt and less costly settlement through the consent decree process.'' 
119 Cong. Rec. 24,598 (1973) (statement of Sen. Tunney). ``A court can 
make its public interest determination based on the competitive impact 
statement and response to public comments alone.'' U.S. Airways, 38 F. 
Supp. 3d at 76 (citing Enova Corp., 107 F. Supp. 2d at 17).

IV. Summary of the Comments and the United States' Response

    The United States received two public comments in response to the 
proposed Final Judgment: One from Missouri Attorney General Eric 
Schmitt and another from Mr. Mark Calmer, an Iowa farmer and small 
agricultural business owner. Consistent with the allegations in the 
United States' Complaint, both comments express concern that ZGC's 
proposed acquisition of certain Bunge elevators will reduce competition 
for the purchase of soybeans and corn along the Mississippi River. 
Missouri Attorney General Schmitt's comment expresses support for the 
divestiture outlined in the proposed Final Judgment. Mr. Calmer's 
comment does not express concerns about the adequacy of the divestiture 
outlined in the proposed Final Judgment nor concerns with Viserion as 
the proposed acquirer.
    In his comment, Missouri Attorney General Schmitt emphasizes that, 
as highlighted in the Complaint, the Transaction would ``eliminat[e] 
crucial competition'' for the purchase of grain from farmers in 
Southeast Missouri. Attorney General Schmitt further states his support 
for the proposed Final Judgement, noting that ``[i]f entered, the 
proposed judgment would replace the competition between Zen-Noh and 
Bunge by establishing an independent player in the market that will 
compete for the purchase of grain. This competition will help ensure 
that Missouri's farmers receive a fair price for the crops that they 
sell.'' See Exhibit A.
    Mr. Calmer, a farmer located in Manson, Iowa, expresses concern 
about increasing concentration in a number of agricultural markets, 
including the grain export, beef packing, fertilizer and chemical, and 
seed industries. With respect to grain elevator operations along the 
Mississippi River, Mr. Calmer states that if the Transaction goes 
through, it will greatly reduce competition for grain purchases. Mr. 
Calmer does not discuss the terms of the proposed Final Judgment. See 
Exhibit B. The proposed Final Judgment will preserve competition for 
the purchase of grain: Where ZGC and Bunge elevators have overlapping 
draw areas with few competitors, one of their facilities will

[[Page 49566]]

be divested. In Iowa, for example, the parties are selling Bunge's 
elevator in McGregor to an independent competitor to maintain 
competition for farmers in that area.
    Nothing in either comment warrants a change to the proposed Final 
Judgment or supports a conclusion that the proposed Final Judgment is 
not in the public interest. As required by the APPA, the comments, with 
the authors' contact information removed, and this response will be 
published in the Federal Register.

V. Conclusion

    After careful consideration of the public comments, the United 
States continues to believe that the proposed Final Judgment provides 
an effective and appropriate remedy for the antitrust violation alleged 
in the Complaint and is therefore in the public interest. The United 
States will move this Court to enter the Final Judgment after the 
comments and this response are published as required by 15 U.S.C. 
16(d).

    Dated: August 30, 2021.

    Respectfully submitted,

For Plaintiff United States of America
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Jill Ptacek,

Attorney for the United States, U.S. Department of Justice, 
Antitrust Division, 450 Fifth Street NW, Suite 8000, Washington, DC 
20530, Tel: (202) 307-6607, Email: [email protected].

ATTORNEY GENERAL OF MISSOURI

ERIC SCHMITT

July 15, 2021

VIA ELECTRONIC MAIL

Robert Lepore, Esq.,
Chief, Transportation, Energy, and Agriculture Section, Antitrust 
Division, Department of Justice, 450 Fifth Street NW, Suite 8000, 
Washington, DC 20530, [email protected].

Re: United States v. Zen-Noh Grain Corporation and Bunge North 
America, Inc., No. 1:21-cv-01482, Comments of Missouri Attorney 
General Eric Schmitt

Dear Mr. Lepore:

    The farmers of Missouri rely on robust competition among 
purchasers of grain to obtain fair compensation for their crops. 
Without robust competition, the farmers' livelihood and their 
ability to continue supplying vital crops to our country are 
threatened.
    The proposed acquisition by Zen-Noh Grain Corporation (``Zen-
Noh'') of grain elevators from Bunge North America, Inc. (``Bunge'') 
poses an existential threat to the farmers of Missouri by 
eliminating crucial competition between Zen-Noh and Bunge for the 
purchase of corn and soybeans. Missouri farmers have expressed 
concern that, post-acquisition, Zen-Noh would control seven 
consecutive grain terminals along the lower Mississippi River. 
Indeed, as the Antitrust Division notes in its Complaint, the 
acquisition would concentrate 95% (in 2019) of Pemiscot County's 
corn and soybean output within one buyer. In short, by eliminating 
one of the few buyers of grain in the Missouri Bootheel, the 
acquisition will lead to lower prices paid to Missouri farmers.
    In light of the unacceptable threat to competition posed by the 
acquisition, I write on behalf of my constituents in Southeast 
Missouri to express my support for the proposed divestiture of grain 
elevators to a suitable buyer. If entered, the proposed judgment 
would replace the competition between Zen-Noh and Bunge by 
establishing an independent player in the market that will compete 
for the purchase of grain. This competition will help ensure that 
Missouri's farmers receive a fair price for the crops that they 
sell.
    I respectfully request that the Court enter the proposed 
judgment to restore competition for the purchase of grain in 
Southeast Missouri.

    Respectfully submitted,

Eric Schmitt,

Attorney General, State of Missouri, Supreme Court Building, 207 W. 
High Street, P.O. Box 899, Jefferson City, MO 65102, Phone: (573) 
751-3321, Fax: (573) 751-0774, www.ago.mo.gov.

Robert Lepore, Chief, Transportation, Energy and Agriculture 
Section, Anti-Trust Division, United States Department of Justice, 
Suite 8000, Liberty Square Building, 450 Fifth Street NW, 
Washington, DC 20530

Dear Sir,

    Thank you for inviting me as a farmer and Ag business owner to 
submit my concerts and comments to your department as invited in an 
article in the High Plains Journal dated June 7, 2021 regarding the 
Department of Justice and Zen-Noh. I appreciate your time and 
attention to this critical matter.
    I started farming in 1972. We are an Iowa farming operation. Our 
background includes approximately 5000 acres of farmland, an Ag 
retail operation, an Ag drainage business and our son has a 500 head 
cattle feedlot operation.
    We are part of the small businesses that made this country. We 
employ 12 full-time employees divided between the different 
entities. We also employ part-time help seasonally. For years, we 
have felt that Anti-Trust laws were not protecting our family 
operated Ag businesses.

Export Houses

    When foreign companies align themselves with grain export 
houses, they don't have to offer competitive prices for our 
products. We need competition to keep prices competitive and allow 
for the average farm operation to have a profit. More grain dealers, 
more export houses, more packers, more fertilizer and chemical 
import companies are needed to keep the American farm engine 
running. We need free trade to keep our costs sustainable.
    If export houses are monopolized along the Mississippi and other 
waterways, I can no longer bid multiple locations and discern 
competitive pricing. If the 48 Bunge elevator sales go through it 
greatly reduces our competition for bids. By Zen-Noh purchasing 
those elevators, they no longer have to bid competitively from other 
export houses controlling a large market share. From where we sit on 
the farm, it appears they are exploiting grain merchandisers by 
limiting competition.
    This isn't the only industry that we see Anti-Trust laws not 
being honored.

Cattle Industry

    As we look at the cattle industry. There are basically 3 packers 
left. JBS, the Brazilian-owned and controlled packer is profiting 
$1000 per head right now while the producer is losing $200-$400/head 
because our government has let the packers monopolize this industry. 
They don't have to bid up on cattle because they know they are the 
only game in town.

Fertilizer and Chemical Industries

    Another instance is the fertilizer and chemical industry. The 
same thing has been allowed to happen, being controlled by 3 major 
companies. Last season we did have some relief because of foreign 
imports of fertilizer. However the MOSAIC company complained, filed 
a law-suit to lessen import by implementing strong tariffs. Our 
government officials went along with it without regard to the family 
farmer's struggle with prices. In less than a year, phosphorus 
fertilizer prices went from $285/ton FOB Dubuque, Iowa on the 
Mississippi to $645/ton. That is a 227% increase in less than 12 
months.

Seed and Grain Industries

    Another Ag sector being controlled is the seed industry. Foreign 
countries are buying up small and large seed companies. Look at 
Bayer (German owned), Syngenta (China owned), all monopolizing this 
critical industry while our government allows foreign ownership and 
control.

Non-Profit Organizations

    Another thing happening in our area and across the United States 
is the activity of allowing Non-profit organizations to buy 
farmland. Non-profit organizations do not pay the state or federal 
taxes the average farm operation has to pay. Locally we are seeing 
the Latter Day Saints Church (Mormon) buying tillable and production 
farmland under the operating name of Deseret Trust Company. Other 
Non-profit entity names the Mormon church controls include Farm 
Reserve Incorporated. We have several young farmers in central Iowa 
trying to either get into farming or buy enough land to grow their 
operation large enough to sustain the business. They can not bid and 
win against these large Non-profits and their seemingly unlimited 
funds.
    As you are probably aware, Bill Gates controls another Non-
profit owning and controlling exorbitant amounts of farmland. These 
groups buy the land, raising the cash rent so high the young and 
local farmer can not get a foothold. It is a rare bank that is going 
to go along with the risk associated with a young farmer paying 
higher cash rent than is profitable. We, as local farmers, have to 
compete with these Non-profits and it is not a level playing field.

[[Page 49567]]

    Non-profits are milking our state and federal governments out of 
approximately $100-$150/acre per year of state and local taxes. By 
our accounts, because these Non-profits do not pay the local and 
state taxes, their burden is passed along to the local farmer, 
smaller communities and rural areas.
    It is time for an investigation into these Non-profit 
organizations

Steel Industry

    Previous administrations have stopped foreign imports which 
caused Us steel prices to skyrocket as major suppliers were only in 
our country. This lack of competition has doubled the steel price--
leading to increased burden on farming operations. We need both. We 
support competition.
    Finally, please stop allowing our country to be sold piece by 
piece to foreign entities. It seems of national interest that 
foreign ownership of our resources is unwise for economic and 
security reasons. Family-owned, hard-working Ag business are giving 
up the fight and giving in to the pressure of foreign ownership and 
the dollars it represents. We support legislation that would limit 
foreign investors ownership and control of American farmland and the 
inputs to support the industry around it.
    From where we sit, it would be easy to believe that large 
corporations are allowed to merge with other conglomerates to the 
benefit of the individuals, governments and share-holders while 
Americans are unprotected even though Anti-Trust laws have been 
established but seemingly unenforced and ignored.
    Please understand the need to open up imports and free trade! We 
as farmers have to compete with our products being exported to 
foreign markets, while our side has controlled input prices by 
tariffs being leveled by our government siding with big business. We 
see the economic impact of our government allowing monopolies 
without regard to Anti-Trust laws.
    I invite more discussion on these matters. Feel free to call my 
cell [redacted]. I also want to personally invite you to be on the 
grounds of our small business and operations. I would welcome the 
conversation.

    Thank you,
Mark Calmer
[Redacted]

[FR Doc. 2021-19097 Filed 9-2-21; 8:45 am]
BILLING CODE 4410-11-P
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