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and vendors for sale in its stores totaling $24,924,968. This
entire amount was purchased from 28 manufacturers and vendors in
Taiwan. Prior to 1994, Payless owned no stores or other
facilities outside the United States. Before 1994, Payless had
no employees located outside the United States, except when
engaged in short-term travel.
In the 1980's, Payless acquired two companies, Knox Lumber
and Somerville Lumber. Payless ran those companies as separate
wholly owned entities with their own boards of directors,
presidents, and operating systems. Both companies had their own
subsidiary headquarters; Knox’s headquarters was in Minnesota,
and Somerville’s headquarters was in Massachusetts. Payless also
maintained regional headquarters located in Indianapolis, Dallas,
Denver, Phoenix, Houston, and Sacramento. Each regional
headquarters is managed by a regional vice president. Each of
the subsidiary and regional headquarters reports to Payless’
corporate headquarters at Two Pershing Square, which houses
Payless’ top corporate managers and staff.
Physical construction of the building that houses Payless’
corporate headquarters, Two Pershing Square, began on or about
October 15, 1984. At all relevant times, legal title to Two
Pershing Square was held by Two Pershing Square, Ltd. (TPS). TPS
was a limited partnership organized on October 15, 1984, under
the laws of the State of Missouri pursuant to an agreement
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