1908003 Informal Interpretation



802.50, 802.51
Anne Six

"Sales” means annual net sales for purposes of 802.50 and 802.51.


From: Six, Anne

Sent: Tuesday, August 13, 2019 2:07:49 PM (UTC-05:00) Eastern Time (US & Canada)

To: [Redacted]

Cc: [Redacted]

Subject: FW: 802.50 / 802.51


“Sales” means annual net sales for purposes of 802.50 and 802.51.



From: [Redacted]

Sent: Thursday, August 8, 2019 1:28:25 PM (UTC-05:00) Eastern Time (US & Canada)

To: [Redacted]

Subject: 802.50 / 802.51

Good afternoon –

I would appreciate clarification on the following: does “sales” as used in 802.50 and 802.51 refer to net sales or gross sales? The question presented in Informal Interpretation 1506005 appears to have assumed the meaning of “sales” in 802.50 and 802.51 tracks 802.11(c), in which case it would be “net sales,” but the distinction between net and gross was not squarely addressed in the response. Thank you.

About 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.