0012001 Informal Interpretation

Michael Verne




December 4, 2000


Michael Verne, Esq.

Federal Trade Commission

Premerger Notification Office

6th Street & Pennsylvania Avenue, NW

Washington, D.C. 20580

Re:Premerger Notification Act - Size of Transaction Determination

Dear Mr. Verne:

I am writing to confirm our conversation last week and tho thank you for your assistance.

During our telephone conference, you answered my question regarding the size of transaction test. Our

client (excess net sales of $100 million) is purchasing 100% of the voting securities of a manufacturing

company (net sales of $18 million). The purchase price for the securities is $7 million. You confirmed

that this transaction does not satisfy Section 7(A)(a)(3)(b).

If the conclusions that I have described in this letter are not consistent with your understanding of the

Act, please contact me at your earliest convenience.

Very truly yours,


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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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