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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8607011 Informal Interpretation

Staff:
Andrew Scanlon
Rule:
7A(c)(7); 7A(c)(8)

Response/Comments

Response: Advised the Above on Aug. 1, 1986 that I agree. Andy Upon later review this appears to be in error regarding the submission of documentary info. for that portion of the transaction subject...

8608007 Informal Interpretation

Staff:
Patrick Sharpe
Rule:
7A(a)(3)

Response/Comments

I concur Patrick Sharpe. Called (redacted) 8-22-86 Andy concurs. Upon later review, the letter appears to ignore the PMN position that any direct assumption of liabilities bargained for between the...

8607004 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
801.51; Item 5

Response/Comments

1. No - Only revenues for sales of those subs. out of establishments in the U.S. 2. No- 3. Sales of U.S. establishment are as a wholesaler Probably no difference where involved 4. Non-Mfg. 5. Co...

8607009 Informal Interpretation

Staff:
Patrick Sharpe
Rule:
801.10

Response/Comments

What (redacted) collects in excess of receivable less reserve for bad debt will be for (redacted) account. (redacted) has agreed to guarantee the receivables. It sounds to me like (redacted) is...

8606010 Informal Interpretation

Staff:
Linda Heban
Rule:
7A(c)(1)

Response/Comments

Spoke w/ (redacted) 6/23/86 Size-of-Transaction must include $13.5 MM acquisition price plus costs reimbursed up to closing. Does not include remainder of contract price because is executory-services...

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