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.

Displaying 3801 - 3820 of 3969

8504005 Informal Interpretation

Staff:
Patrick Sharpe
Rule:
801.10(c)(2)

Response/Comments

I believe this is a $19 mm plus transaction. and is reportable under H-S-R. Patrick Agreed Disagreed DA VC AS JS ST called (redacted) 4/12/85 consensus opinion is that $13 mm payments are included in...

8503002 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
802.20

Response/Comments

I informed (redacted) that I agree on basis of either joint venture analysis or voting securities of issuer within a person analysis. Either results in § 802.20 exemption. 3/20/85 Wayne Kaplan

8503003 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
801.1 (b); 801.11

Response/Comments

I notified (redacted) on 3/18/85 that the letter is accurate as far as it goes. Inaddition, there must not be any intent to structure the transaction to avoid a filing(i.e. 801.90 avoidance).

8502011 Informal Interpretation

Staff:
Addie Williams
Rule:
Item 7

Response/Comments

3/4/85 Acknowledged receipt of letter and indicated agreement that Items 5-9should reflect data relevant [indecipherable]. Upon later review it is clear that this letter is incomplete and no general...

8502010 Informal Interpretation

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

Response/Comments

2/27/85 T/C Scanlon/(redacted). I explained that HSR did not recognize thegroup concept of SEC and that the individuals should be considered separately(aggregating spouse and minor children) and...

8502007 Informal Interpretation

Staff:
Wayne Kaplan
Rule:
801.1(b)

Response/Comments

2/19/85 called (redacted) and he described partners. No overlap w/ acquiredperson in Addies transaction and 1st transaction is'nt ready. (redacted) will call if that one proceeds. Wayne Kaplan...

8502004 Informal Interpretation

Staff:
Andrew Scanlon
Rule:
802.50; 802.20

Response/Comments

2/11/85 T/C Scanlon (redacted). Told (redacted) my advice to him as described inthis letter was inaccurate and that the facts described in this letter constitute areportable transaction since the...

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