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HSR Informal Interpretations

0903007 Informal Interpretation

… party. Myunderstanding is that this transaction is not HSR reportable regardless of thesize of the transaction or the … itscontrolling stake in Limited Partnership A with no HSR reporting obligationsince such position was acquired prior … less than a 100% interestin a limited partnership was never reportable. … 0903007 Informal Interpretation …
Date
Rule
802.30
Agree.
HSR Informal Interpretations

0903002 Informal Interpretation

… primary duty under the Constitution is to audit and report on theaccounts of all the departments and offices of … with itself, the Sovereign and the Monetary Authority asthe reporting persons and allocates the beneficial ownership of …
Date
Rule
801.1
Agree Fund is not an entity for HSR purposes.
HSR Informal Interpretations

0902004 Informal Interpretation

… Improvements Act("Act") and therefore do not require reporting under the Act. In ourcall, you confirmed to us … applies and the Buyer and theSeller need not file and report the transaction under the Act. Wewould appreciate …
Date
Rule
15 USC 18a(c)(11)
Agree. JF and MV concur.
Cases and Proceedings
Commissioner Statements

Concurring Statement of Commissioner Jon Leibowitz, FTC Staff Report: Self-Regulatory Principles for Online Behavioral Advertising

… Statement of Commissioner Jon Leibowitz, FTC Staff Report: Self-Regulatory Principles for Online Behavioral … Statement of Commissioner Jon Leibowitz, FTC Staff Report: Self-Regulatory Principles for Online Behavioral … Statement of Commissioner Jon Leibowitz, FTC Staff Report: Self-Regulatory Principles for Online Behavioral …
Date
By
Jon Leibowitz, Former Chairman
Federal Trade Commission Staff Report: Self-Regulatory Principles For Online Be…
Cases and Proceedings
Commissioner Statements

Concurring Statement of Commissioner Pamela Jones Harbour, FTC Staff Report: Self-Regulatory Principles for Online Behavioral Advertising

… Statement of Commissioner Pamela Jones Harbour, FTC Staff Report: Self-Regulatory Principles for Online Behavioral … Statement of Commissioner Pamela Jones Harbour, FTC Staff Report: Self-Regulatory Principles for Online Behavioral … Statement of Commissioner Pamela Jones Harbour, FTC Staff Report: Self-Regulatory Principles for Online Behavioral …
Date
By
Pamela Jones Harbour, Former Commissioner
HSR Informal Interpretations

0902005 Informal Interpretation

… first two options. We believe thefirst alternative is nonreportable unless X decides not to go forward with … that the third alternativeinvolves two potentially reportable transactions, the transfer of additionalexclusive … those exclusive rights byX if it exercises its option, with reporting required if all the relevantthresholds are met. In …
Date
Rule
801.2
reportable because X is not licensing the rights to the IP for the retained indications to Y. It is entering into a contractual arrangement with Y to research, develop and commercialize the compound...
HSR Informal Interpretations

0901006 Informal Interpretation

… like to confirm the Staffs opinion regarding potential reporting obligations in the transaction described below. … understanding that this transaction would be exempt from reporting obligations as a transaction in the ordinary … of the portfolio must be separately analyzed for potential reporting obligations). As described above, in this …
Date
Rule
15 USC 18a(c)(1) 7A(c)(1)
Agree.
HSR Informal Interpretations

0901008 Informal Interpretation

… HSR Threshold/Exemption Analysis Hi Mike, I have an HSR reporting analysis I'd like your guidance on. The … for cash and voting securities so there are potentially two reportable transactions, (1) the acquisition by Company A of … (the "Stock Acquisition"). The LLC Acquisition is not reportable and the Stock Acquisition is probably exempt, as …
Date
Rule
802.30, 802.9
Agree.
Federal Register Notice

Charges for Certain Disclosures - 612(f) Fair Credit Reporting Act

… Charges for Certain Disclosures - 612(f) Fair Credit Reporting Act Federal Register Notice Charges for Certain Disclosures - 612(f) Fair Credit Reporting Act 081229chargesforcertaindisclosures.pdf … Charges for Certain Disclosures - 612(f) Fair Credit Reporting Act …
Date
HSR Informal Interpretations

0812004 Informal Interpretation

… the size of transaction test and therefore will notbe reportable under HSR. Company A isreorganizing in … B's acquisition of 50% of the new common stock willnot be a reportable transaction because it will not meet the size … falls below the current $63.1 million sizeof transaction reporting threshold. Should any of the debt be converted at …
Date
Rule
15 USC 18a(c)(3)-7A(c)(3), 801.10, 802.31
I agree -nothing reportable now. Also nothing reportable if the debt is later converted to voting securities because B will already hold 50%.
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