Common use of Section 355 Clause in Contracts

Section 355. Neither the execution and delivery of this Agreement nor the consummation of the Transactions are reasonably likely to have the effect of causing (a) the Distribution to be taxable in any respect to Lucent or its stockholders, or (b) the Private Letter Ruling to be inapplicable in any respect.

Section 355. Neither the execution and delivery of this Agreement or the Stock Purchase Agreement, nor the consummation of the Transactions transactions contemplated hereby or thereby or the Equity Issuances are reasonably likely to have the effect of causing (a) the Distribution to be taxable in any respect to Lucent or its stockholders, or (b) the Private Letter Ruling to be inapplicable in any respect.

Section 355. Neither the execution and delivery of this Agreement or the Conversion Agreement, nor the consummation of the Transactions transactions contemplated hereby or thereby or the Equity Issuances are reasonably likely to have the effect of causing (a) the Distribution to be taxable in any respect to Lucent or its stockholders, or (b) the Private Letter Ruling to be inapplicable in any respect.