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To: Uncle Frank who wrote (34190)	11/2/2000 10:32:16 AM
From: mmbw	Read Replies (2) \| Respond to of 54805

Frank, please help me understand what this will mean for QCOM investors. Is it good news, bad news or just news? quicken.excite.com QUALCOMM Receives IRS Ruling on Proposed Spin-Off of QUALCOMM CDMA Technologies Thursday, November 2, 2000 07:33 AM SAN DIEGO--(BUSINESS WIRE)--Nov. 2, 2000--QUALCOMM Incorporated (Nasdaq: QCOM, news, msgs) today announced that it has received a ruling from the Internal Revenue Service (IRS) indicating that the proposed spin-off of its integrated circuits and system software business (QUALCOMM CDMA Technologies), referred to as QUALCOMM Spinco ("Spinco"), should be a tax-free distribution to QUALCOMM and its stockholders, provided that the spin-off is executed in accordance with the representations made in the ruling request. QUALCOMM stockholders of record as of the record date, which is yet to be determined, would receive shares of Spinco common stock, at a ratio to be determined, and cash payments for fractional shares. Cash received in lieu of fractional shares would be taxable for U.S. federal income tax purposes. The Company also announced that consideration of the Initial Public Offering of Spinco common stock will be postponed until January of 2001 due to unfavorable market conditions. Martha