1207013 Informal Interpretation

Date:
Rule:
802(e)(1)
Staff:
Shelia Clark-Coleman
Response/Comments:

  – Agree.  J Ferkingstad concurs.

Question

From: (Redacted)
Sent: Friday, July 27, 2012 3:01 PM
To: Clark-Coleman, Sheila
Subject: Hart-Scott-Rodino Notification Exemption

July27, 2012
Ms. Sheila Clark-Coleman
Federal Trade Commission
Bureau of Competition
Pre-Merger Notification Office
600 Pennsylvania Avenue, NW
Room 303
Washington, D.C. 20580

Re:Hart-Scott-Rodino Notification Exemption

DearMs. Clark-Coleman,

Thisconfirms our conversation earlier today relating to the Hart-Scott-RodinoNotification requirement and HSR Rule Section 802.2(e).

Iexplained that my client intends to purchase a hotel which includes a detachedcasino, which casino is and shall continue to be operated by an unaffiliatedthird party, that the relationship between my client and the casino operatorwill be one of Landlord-Lessee, and that my client will not own any of thegaming assets.

Youconfirmed that the described transaction would be exempt from the HSRNotification requirements and Rule Section 802.2(e).

Iwould appreciate receiving from you your written confirmation that thedescribed transaction would be exempt from the HSR Notification requirementsand Rule Section 802. 2(e).

About Informal Interpretations

Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

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