I think S&C is fine - they are helping us with CFTC issues related to online 
trading and Energy Desk.com seems somwhat related.




Sara Shackleton
11/16/99 12:21 PM
To: Mark Taylor/HOU/ECT@ECT
cc:  
Subject: JAPRO Gruppen Aktiebolag

Per my voice mail.  Let me know what you think.  SS
---------------------- Forwarded by Sara Shackleton/HOU/ECT on 11/16/99 12:21 
PM ---------------------------


Sara Shackleton
11/09/99 10:48 AM
To: Mark Taylor/HOU/ECT@ECT
cc:  
Subject: JAPRO Gruppen Aktiebolag

Martin sent this message to London and Michael advised that Sullivan & 
Cromwell be retained.  With respect to interest by the CFTC in  the proposed 
transaction, would you agree that the same law firm advise on that issue as 
well?  Makes sense to me.  Also, what is Energydesk.com LImited?  Sara
---------------------- Forwarded by Sara Shackleton/HOU/ECT on 11/09/99 10:45 
AM ---------------------------


Martin Rosell
11/09/99 09:47 AM
To: Sara Shackleton/HOU/ECT@ECT
cc:  
Subject: JAPRO Gruppen Aktiebolag

Sara,

I hope you're doing well.  Please see my note to Paul below.  It feels a bit 
like an overkill to turn directly to Sullivan & Cromwell (as suggested by 
Micheal) in respect of a USD 1.25 million transaction.  The target consists 
of about a dozen employees and its business is to advise local energy 
companies on appropriate risk management structures and routines.  My 
understanding is that the target never advises on what trading positions its 
customers should take.  Could there possibly be an interest for the CFTC in 
this worth investigating further?!  I believe the Energydesk.com Limited 
people intend to let Japro survive and continue its current operations (as 
well as serving Energydes.com's customers in the future).  Please advise!

Martin
---------------------- Forwarded by Martin Rosell/OSL/ECT on 99-11-09 12:59 
---------------------------


Fiona Lavelle
99-11-04 16:07
To: Martin Rosell/OSL/ECT@ECT
cc: Michael R Brown/LON/ECT@ECT 
Subject: Sullivan & Cromwell



---------------------- Forwarded by Martin Rosell/OSL/ECT on 99-11-09 13:00 
---------------------------


Martin Rosell
99-11-09 12:07
To: Paul Simons/LON/ECT@ECT
cc:  
Subject: JAPRO Gruppen Aktiebolag

Paul, 

The above entity is a Swedish limited liability company which Energydesk.com 
Limited intends to acquire.  According to the company's Articles, it may 
prepare  analyses, give information, and engage in advisory and consulting 
activities with respect to risk management, energy and power trading; carry 
out strategic and other analyses and advise on strategic and organisation 
development; engage in IT based consulting as well as in any other activity 
ancillary with any the foregoing.  Principally, the company acts as a risk 
management consultant for small and medium seized energy companies in the 
Sweden and Finland.

Will the acquisition give rise to any SFA concerns?!  Despite the general 
extraterritorial application of US securities laws, I'd guess an acquisition 
of a minor Swedish-based operation active in the Nordic market by a U.K. 
entity would be too remote to cause attraction over there.  I may check it 
anyhow, but do you have a feel for the topic?

Martin