SEC Division of Corporation Finance no-action letter: Stichting Pensioenfonds ABP

The Division of Corporation Finance will not recommend enforcement action to the Commission if Stichting Pensioenfonds ABP reports beneficial ownership on Schedule 13G pursuant to Rule 13d-1(b). Stichting Pensioenfonds ABP may not use Schedule 13G if it acquires the subject securities with the purpose or effect of changing or influencing control of the issuer. This position is based on representations regarding the comparability of foreign and United States laws governing the entity and an undertaking to furnish information otherwise required by Schedule 13D upon request.

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Securities Exchange Act of 1934 Rule 13d-1(b)

May 7, 2004

George Spera, Esq. Shearman & Sterling LLP 599 Lexington Avenue New York, NY 10022

Re: Stichting Pensioenfonds ABP Incoming letter dated May 4, 2004

Dear Mr. Spera:

We are responding to your letter dated May 4, 2004, as supplemented by conversations with the staff. We have attached a photocopy of your correspondence to avoid having to recite a summary of the facts set forth in your letter. Unless otherwise noted, each capitalized term in our letter has the same meaning as defined in your letter.

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