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Advocacy Filings

FTC Staff Comment Before the Massachusetts Board of Registration in Medicine Concerning Proposed Regulation to Share Investigatory Records and Other Confidential Information With Designated State and Federal Agencies

… Board of Registration in Medicine Concerning Proposed Regulation to Share Investigatory Records and Other Confidential … Board of Registration in Medicine Concerning Proposed Regulation to Share Investigatory Records and Other Confidential … Board of Registration in Medicine Concerning Proposed Regulation to Share Investigatory Records and Other Confidential …
Date
Matter Number
P854646
Advisory Opinions

Advisory opinion concerning the legality of the American Society of Internal Medicine's proposal to develop and disseminate relative value guides

… Internal Medicine's proposal to develop and disseminate relative value guides Advisory opinion concerning the legality … Internal Medicine's proposal to develop and disseminate relative value guides Proposed development of a relative value guide for physician services to be distributed …
Date
Proposed development of a relative value guide for physician services to be distributed to member internists would be likely to have anticompetitive effects that probably would not be outweighed by...
HSR Informal Interpretations

8504005 Informal Interpretation

… of the acquisition price for purposes of determining the dollar value of assets to be acquired. Pursuant to your … will also assume payments on the $13 mm loan, But counsel claims no one assumes liability for the loan?? Issue: The … In the factual situation described above, no similar consideration flows to S since S has no personal …
Date
Rule
801.10(c)(2)
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...
HSR Informal Interpretations

8504002 Informal Interpretation

… B, a corporation with assets of $1 million according to its last regularly prepared balance sheet. A and B are general partners of a limited …
Date
Rule
801.1
see notes on Page 2. 4/9/85 T/C Scanlon/(redacted). I advised (redacted) thatalthough he is correct in his statement that partnerships
HSR Informal Interpretations

8504001 Informal Interpretation

… confirmed the previous advice given to us by your office relating to the calculation of the total assets of an entity used Footnote for … effectuating an acquisition are not to be included in calculating the “size” of the entity. For example, if funds were …
Date
Rule
801.11(e)
I concur. 4-8-85. Patrick
HSR Informal Interpretations

8504006 Informal Interpretation

… Informal Interpretation (redacted) April 15, 1985 Wayne Kaplan, Esq. Federal Trade Commission Bureau of Competition … acquisition of voting securities of (redacted) Dear Mr. Kaplan: This confirms our conversation of April 15, 1985 in … fact that the corporate structure which was actually in place at the time of the acquisition varied from that …
Date
Rule
803.2 (Item 1(j))
No written response.
HSR Informal Interpretations

8504008 Informal Interpretation

… of (redacted). The sole asset of (redacted) is the land on which (redacted) horse business is based. (redacted) … name (redacted). the remainder of (redacted) assets are unrelated to the horse business and apparently account for … appears to have been comprised substantially of regular sales of yearlings, weanlings, brood mares, racing stock …
Date
Rule
802.1
No written response; See 8504010 (confirmation letter)
HSR Informal Interpretations

8504011 Informal Interpretation

… D.C. 20580 Dear Mr. Scanlon: Thank you for your explanations by telephone today and on April 18, 1985 of certain matters relating to filing the current Notification and Request Form … this letter is to confirm my understanding of your explanations which, for the sake of clarity, I have reduced to …
Date
Rule
801.1(b)
OK AMS
HSR Informal Interpretations

8504013 Informal Interpretation

… Interpretation (redacted) April 24, 1985 Mr. Wayne Kaplan Room 301 Federal Trade Commission Washington, D.C. 20580 Re:(redacted) Dear Mr. Kaplan: This letter is to confirm our telephone conversation of … entities. (redacted) a general partnership. The following relationships exist among these various entities: 1.(redacted) …
Date
Rule
802.20; 801.10
No written comments
HSR Informal Interpretations

8503002 Informal Interpretation

… Informal Interpretation (redacted) March 18, 1985 Wayne Kaplan, Esq. Room 301 Federal Trade Commission Washington, D.C. … the Premerger Notification Rules - 16CFR 802.20 Dear Mr. Kaplan: This is to confirm our recent conversation concerning … million. (redacted) are not affiliated. (redacted) contemplates expanding into the group life and health insurance …
Date
Rule
802.20
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
HSR Informal Interpretations

8503003 Informal Interpretation

… (redacted) March 18, 1985 HAND DELIVERY Wayne Kaplan Federal Trade Commission Room 301 [indecipherable] … D.C. 20580 Re:Interpretation of Control and Calculation of Total Assets under the Pre-Merger Notification Regulations Dear Mr. Kaplan: This will confirm our telephone …
Date
Rule
801.1 (b); 801.11
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).
Advisory Opinions

Opinion 85-1

… refusal to serve consumers who provide their own casket violates the funeral rule. opinion_85-1.pdf Advisory Opinion … …
Date
Expresses view that refusal to serve consumers who provide their own casket violates the funeral rule.
HSR Informal Interpretations

8502011 Informal Interpretation

… Ms. Williams: Thank you for your assistance today in explaining to me by telephone certain requirements of Item 7 of … This letter is to confirm my understanding of your explanation of those requirements as they are set forth in the … Item 7(c)(iv), certain information for certain industrial classifications must be provided for each establishment from …
Date
Rule
Item 7
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...
HSR Informal Interpretations

8503001 Informal Interpretation

… (redacted) that (redacted) fro which it has expended large sums of money and faces further large expenditures before the product is suitable for the … of (redacted) and the present joint venture arrangement centers upon the acquisition of assets which are located in …
Date
Rule
801.40; 802.50; 802.51
No written comments
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