In Y.N. Patt's paper “Variable Length Tree Structures Having Minimum Average Search Time” [ Comm . ACM 12 (Feb. 1969)], the tree structures obtained are not actually optimal with respect to the two-dimensional chaining devised by Sussenguth in his 1963 paper. This note points out that the result can be described as “optimal” only under the constraint—which Patt implicity assumes—that no key be allowed to prefix another.