8501005 Informal Interpretation

Andrew Scanlon

T/C 2/5/84 Scanlon (redacted) Inaccurate after determination that acquiring andacquired have $1 mm in same SIC Code all 50% acquisitions in which the acquiredderived revenue in that SIC & had sales or assets in excess of 10 mm must belisted AMS. He will send another letter per phone conversation 2/5/84 [sic].



January 31, 1985

Mr. Anthony [sic] Scanlon
Premerger Notification Office
Bureau of Competition
Seventh Street and Pennsylvania Avenue, N.W.
Washington, D.C. 20580

Dear Mr. Scanlon:

Thank you for your assistance today in explaining to me by telephone the requirements of Item 9 of the current Notification and Request Form For Certain Mergers and Acquisitions (FTC Form C 4) (rev. 9/84). This letter is to confirm my understanding of your explanation of those requirements as they are set forth in the Instructions that accompany that form.

The Instructions provide that, for purposes of Item 9, a previous acquisition should only be listed if, in addition to satisfying the other requirements of Item 9, it had annual net sales or total assets greater than $10 million in the year prior to the acquisition. This requirement is only satisfied if those net sales or total assets were all in the same 4 digit industry, that industry being the same 4 digit industry that is the basis for listing under Item 9.

Very truly yours,


cc: (redacted)

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