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.
Displaying 4301 - 4320 of 4469
Date
Rule
7A(c)(1); see 802.2
This change will not will not [sic] change advice given earlier still exempt. Patrick. Called (redacted) 5-23-85
File
Original Image File
(167.54 KB)
Date
Rule
801.10(c)(2)
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...
File
Original Image File
(234.79 KB)
Date
Rule
801.1
see notes on Page 2. 4/9/85 T/C Scanlon/(redacted). I advised (redacted) thatalthough he is correct in his statement that partnerships
File
Original Image File
(233.67 KB)
Date
Rule
801.11(e)
I concur. 4-8-85. Patrick
File
Original Image File
(215.06 KB)
Date
Rule
803.2 (Item 1(j))
No written response.
File
Original Image File
(124.39 KB)
Date
Rule
802.1
No written response; See 8504010 (confirmation letter)
File
Original Image File
(524.99 KB)
Date
Rule
802.1; 7A(g)
My concern is not with the acquisition but that nobody thought about H-S-R untilafter closing; see 8504008 (letter requesting advice)
File
Original Image File
(308.89 KB)
Date
Rule
802.20; 801.10
No written comments
File
Original Image File
(412.37 KB)
Date
Rule
801.11(e)
called 5-2-85. I concur with letter of April 3, 1985. Patrick
File
Original Image File
(115.56 KB)
Date
Rule
7A(c)(4)
No written comments
File
Original Image File
(3.19 MB)
Date
Rule
802.20
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
File
Original Image File
(390.86 KB)
Date
Rule
801.1 (b); 801.11
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).
File
Original Image File
(279.01 KB)
Date
Rule
Item 7
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...
File
Original Image File
(157.54 KB)
Date
Rule
801.40; 802.50; 802.51
No written comments
File
Original Image File
(1.13 MB)
Date
Rule
7A(c)(8)
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...
File
Original Image File
(415.65 KB)
Date
Rule
801.1(b)
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
File
Original Image File
(283.51 KB)
Date
Rule
802.40
2/11/85 Acknowledged receipt of letter and indicated to (redacted) that as long asno transfer of assets takes place [indecipherable].
File
Original Image File
(148.88 KB)
Date
Rule
802.50; 802.20
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...
File
Original Image File
(345.77 KB)
Date
Rule
802.50; 801.15
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 attached...
File
Original Image File
(812.73 KB)
Displaying 4301 - 4320 of 4469