Acknowledging that Indian law prevents it from owning the entire Hutchison Essar (HE) stake it had offered to purchase from Hutchison Telecommunications International (HTI), Vodafone clarified, in a letter to India’s finance ministry, that its interest in HE would amount only to 52%. After fending off several other bidders, Vodafone announced in February that it had agreed to purchase HTI’s 67% economic interest in HE, the fourth largest wireless operator in India with a 16.4% share of that market. At the urging of parties that claim the U.S. $11.1 billion transaction would breach India’s 74% cap on foreign investment, India’s foreign investment promotion board has deferred a decision on the deal. Although HTI owns 52% of HE directly, an additional 15% is held on HTI’s behalf by firms owned by two Indian nationals, over which HTI holds call options. The remainder of HE (33%) is held by Essar, an Indian conglomerate that has structured its stake so that 22% is held offshore. In an attempt to eliminate confusion arising from earlier pronouncements that the $11.1 billion purchase price constitutes “consideration paid by Vodafone to acquire 67% of [HE],” Vodafone explained to D.K. Singh, the director of India’s finance ministry, that Vodafone had merely intended to provide “a simplified tabular summary of a complex transaction” and that “the [call] options could not be exercised within the existing shareholder structure if they resulted in a transfer to us or another non-resident entity.” Accordingly, Vodafone would be left with a direct 52% interest in HE that Vodafone asserted would be “legal.”