Request for Waiver of Rule 16(a) for Karnavati Holdings, Inc.

Karnavati will not be operating in California except through its subsidiaries, and therefore, under Cal. Corp. Code § 191(a), is not required to qualify to transact intrastate business. Applicants state that because Karnavati, will not be transacting business in California as that term is defined by Cal. Corp. § 191(a), it is not required by Cal. Corp. § 191(b) to qualify to transact business in California. Applicants submit that requiring Karnavati to qualify to transact intrastate business for the sole purpose of satisfying Rule16(a) will impose administrative burdens on the company that it would not otherwise incur but for having qualified and, which are not related to the issues before the Commission in this application.