    ADI and its related corporations buy and sell manufactured

homes in the same manner.

     Manufactured homes are constructed at a factory location and

are then transported directly to homesites of retail purchasers.

     ADI has been selling manufactured homes for more than 30

years, and ADI has become the largest seller of manufactured

homes in Arizona and one of the largest sellers of manufactured

homes in the Southwestern United States.   In recent years, ADI

has expanded its sales of manufactured homes to 192 locations in

22 states.

     From the 1970s through the late 1990s, ADI purchased

completed manufactured homes from unrelated manufacturers and

sold the manufactured homes directly to retail customers using

individual salespersons who worked for ADI as employees.

 long it takes for the customer’s homesite to be completed.

     Under the written contracts that are entered into (between

ADI and the manufacturers, between the independent salespersons

and ADI, and between retail customers and the independent
                               - 7 -
salespersons), upon completion the manufactured homes are sold by

the manufacturers to ADI, by ADI to the independent salespersons,

and by the independent salespersons to the retail customers.

     Of manufactured homes sold by ADI, approximately 90 percent

are custom ordered by retail customers based on the decisions and

selections customers make in their discussions and negotiations

with the independent