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.

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8705001 Informal Interpretation

Staff:
Patrick Sharpe
Rule:
802.40

Response/Comments

[response 1]-Called (redacted) MAY 15, 1987. The PMN Off has determined that this is exempt under 802.40.-[response 2]-I concur with this letter. Furthermore, (redacted) confirmed that (redacted)...

8704002 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
801.11(e)

Response/Comments

Based on the analysis that this is one indissolvable transaction it appears that no filing by (redacted) is required since the 801.11(e) size-of-person calculation results in his person being less...

8704007 Informal Interpretation

Staff:
Patrick Sharp

Response/Comments

[note 1-sketch of joint venture] - The parties are forming a joint adventure to manage a portion of their assets, not all of their assets. Although this transaction meets the size-of-person test, it...

8504004 Informal Interpretation

Staff:
Patrick Sharpe
Rule:
802.20; 801.1(f)

Response/Comments

Comment: The initial transaction is exempt (32% of v/s) under Section 802.20. The option is reported if and when it is exercised. Although it is one part ofBeneficial ownership, that is the right to...

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