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 3781 - 3800 of 3924

8501001 Informal Interpretation

Staff:
Staff Comment: *** Between $450 and $500 MM
Rule:
802.1; 802.2

Response/Comments

Are they buying this retail space to operate or as an investment? They are buyingthese rental building in order to resell as condominiums. Who is making theacquisition? We are not sure yet. Perhaps a...

8501002 Informal Interpretation

Staff:
Patrick Sharpe
Rule:
801.10; 802.20

Response/Comments

comments: Wayne Kaplan said contingent payments should be estimated according to 801.10 of the rules and included in transaction price. Andy Scanlon agrees and added that they indicate a face value...

8501004 Informal Interpretation

Staff:
Staff Comment: ** there is no retail space included
Rule:
7A(c)(1); 802.1; now See 802.2

Response/Comments

The FTC staff has historically said that the acquisition of office buildings is generally exempt (no retail space or other income producing properties included) under § 802.1 of the rules. Is this...

8412001 Informal Interpretation

Staff:
Patrick Sharpe
Rule:
802.20; 802.50

Response/Comments

See diagram. We examine the 802.20 & 802.50 by issuer. Accordingly, thesetransactions are exempt given the information provided. [Note: No Facts, dollar values given, but enough info (less...

8412003 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
801.40; 802.20

Response/Comments

12/6/84 (redacted) 2d letter. Pg1 1. Refers to acquisitions plural – if so newly formed entity rule will not protect 2d etc acquisitions Pg2 2. refers to several sellers – if they are outside. Pg3 3...

8411008 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
801.40; 802.20; 801.11

Response/Comments

See attached note re [indecipherable] of advice transmitted by telephone to(redacted) on 11/30. [Indecipherable] and by W.E.K. on 11/26/84. The fact thatB is making loans and guarantees to the newly...

8411001 Informal Interpretation

Staff:
Andrew Scanlon
Rule:
803.2

Response/Comments

11/6/84 Called [indecipherable] - He is not available. told his secy that we do notrespond by mail but that I agree with the statements in this letter & confirm his understanding AMS 11/6/84

8410007 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
803.2

Response/Comments

10/29/ (redacted) letter response 10/30/84. 1. Not significantly except to extent system fails [indecipherable] we have to spend time looking for necessary documents. 2. Yes - See p33524 - if...

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