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.

Learn more about Informal Interpretations.

Displaying 3741 - 3760 of 3908

8504005 Informal Interpretation

Staff:
Patrick Sharpe
Rule:
801.10(c)(2)

Response/Comments

I believe this is a $19 mm plus transaction. and is reportable under H-S-R. Patrick Agreed Disagreed DA VC AS JS ST called (redacted) 4/12/85 consensus opinion is that $13 mm payments are included in...

8503002 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
802.20

Response/Comments

I informed (redacted) that I agree on basis of either joint venture analysis or voting securities of issuer within a person analysis. Either results in § 802.20 exemption. 3/20/85 Wayne Kaplan

8503003 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
801.1 (b); 801.11

Response/Comments

I notified (redacted) on 3/18/85 that the letter is accurate as far as it goes. Inaddition, there must not be any intent to structure the transaction to avoid a filing(i.e. 801.90 avoidance).

8502011 Informal Interpretation

Staff:
Addie Williams
Rule:
Item 7

Response/Comments

3/4/85 Acknowledged receipt of letter and indicated agreement that Items 5-9should reflect data relevant [indecipherable]. Upon later review it is clear that this letter is incomplete and no general...

8502010 Informal Interpretation

Staff:
Andrew Scanlon
Rule:
7A(c)(8)

Response/Comments

2/27/85 T/C Scanlon/(redacted). I explained that HSR did not recognize thegroup concept of SEC and that the individuals should be considered separately(aggregating spouse and minor children) and...

8502007 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
801.1(b)

Response/Comments

2/19/85 called (redacted) and he described partners. No overlap w/ acquiredperson in Addies transaction and 1st transaction is'nt ready. (redacted) will call if that one proceeds. Wayne Kaplan...

8502004 Informal Interpretation

Staff:
Andrew Scanlon
Rule:
802.50; 802.20

Response/Comments

2/11/85 T/C Scanlon (redacted). Told (redacted) my advice to him as described inthis letter was inaccurate and that the facts described in this letter constitute areportable transaction since the...

8502003 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
802.50; 801.15

Response/Comments

Dana objects on basis 802.20 not w/in 801.15 & suggests parties file. I notified(redacted) secretary on 2/8/85 that the letter is inaccurate and that a filing is required by both parties. See...

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