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.

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2101003 Informal Interpretation

Staff:
Nora Whitehead
Rule:
802.30

Response/Comments

No, it doesn’t qualify for 802.30 because A controls B (which controls C) through the contractual right to appoint directors and not via ownership of voting securities.

2101005 Informal Interpretation

Staff:
Kathryn Walsh
Rule:
802.2

Response/Comments

We agree that the management contracts could be incidental to the timeshare business as long as Target owns the properties it manages; however, the assets of the management business itself would not...

2012001 Informal Interpretation

Staff:
Kathryn Walsh
Rule:
802.9

Response/Comments

Your scenario below does not preclude 802.9, but, as you are in possession of all the facts related to this inquiry, you will need to make the final call and be prepared to defend any decision not to...

2012002 Informal Interpretation

Staff:
Kathryn Walsh
Rule:
801.30

Response/Comments

Your transaction would not qualify for CTO status – the CVR is not a “present cash payment” (see PNPM #218) as it involves a potential future cash payment.

2010002 Informal Interpretation

Staff:
Anne Six
Rule:
801.1, 7A(a)(2)

Response/Comments

If all of the manufacturing is performed by third parties, your client is not engaged in manufacturing for purposes of Section 7A(a)(2) and Section 801.1(j).

2010006 Informal Interpretation

Staff:
Sam Sheinberg
Rule:
Item 5

Response/Comments

Our suggestion is to ask the business people which of the available NAPCS descriptions is closest to the product your client manufactures that relates to the 6-digit code and report the revenues...

2010001 Informal Interpretation

Staff:
Karen Berg
Rule:
803.5

Response/Comments

Yes Yes. Be sure that the Affidavit identifies the signatory along with his/her title and entity, and states that he or she is authorized to make the affidavit on behalf of the UPE. The signatory...

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