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HSR Informal Interpretations

8609010 Informal Interpretation

… HAND DELIVERY Wayne Kaplan, Esq. Pre-Merger Notification Office Federal Trade Commission 6th Street and Pennsylvania … conversation of today in which you informed me that the Federal Trade Commission will not challenge as violative …
Date
Rule
7A
Letter is incorrect. I cannot bind the Commission. I merely advised (redacted) that we advise that no filing is necessary. We refers to the premerger office, and the FTC and Dept. of Justice are not...
HSR Informal Interpretations

8609001 Informal Interpretation

… September 5, 1986 Mr. Patrick Sharpe Premerger Notification Office Bureau of Competition Room 303 Federal Trade … of this request is attached hereto for your easy reference. The purpose of this letter is to confirm our August 26,1986, …
Date
Rule
802.20
I concur. Patrick 9/23/86
HSR Informal Interpretations

8609002 Informal Interpretation

… Esquire Federal Trade Commission Premerger Notification Office 6th and Pennsylvania Avenue, N.W. Washington, D.C. … we are writing this letter to respectfully bring to the Federal Trade Commissions attention a transaction, which …
Date
Rule
7A(c)(1
9/10/86 Transaction would be scrutinized carefully by PMN Office because structure of transaction lends itself easily to evasion of reporting requirement and it may occur in cases where there could be...
HSR Informal Interpretations

8609003 Informal Interpretation

… Sharpe, Compliance Specialist Premerger Notification Office Bureau of Competition Federal Trade Commission 6th … 1986. Based upon my prior conversation with your office and the fact there has been no reply to my August 27, 1986 …
Date
Rule
801.10
OK. I concur. Called 9-17-86
HSR Informal Interpretations

8608005 Informal Interpretation

… August 14, 1986 Mr. Wayne Kaplan Premerger Notification Office Bureau of Competition Room 301 Federal Trade … Dear Mr. Kaplan: At your suggestion, I have put in writing the factual scenario we discussed in our August 8 telephone …
Date
Rule
801.10; 801.40; 802.20
No written response will be given. A must determine in good faith fair market value of the v.s. of X it will obtain and if below $15.0MM in value then none of above transactions appear to be...
HSR Informal Interpretations

8608007 Informal Interpretation

… Esq. Federal Trade Commission Premerger Notification Office Bureau of Competition Room 301 Washington, D.C. 20580 … Sharpe: This will confirm your telephonic advice today that the following transaction satisfies the minimum value …
Date
Rule
7A(a)(3)
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...
HSR Informal Interpretations

8608008 Informal Interpretation

… Sharpe, Esq. Compliance Specialist Pre-Merger Notification Office Room 303 Federal Trade Commission 6th Street and … of Wednesday, August 20, 1986, I hereby request that the Pre-Merger Notification Office of the Federal Trade …
Date
Rule
801.1(a)(3)
See Page 3 for Graphic Illustration
HSR Informal Interpretations

8608010 Informal Interpretation

… August 25, 1986 Mr. Patrick Sharpe Premerger Notification Office Room 303 Bureau of Competition Federal Trade … and availability of exemptions under, 1[5] U.S.C. 18a (and the regulation promulgated thereunder) in connection with a …
Date
Rule
802.20
This transaction (or transactions) exempt under 802.20 Called (redacted) 8-26-86
HSR Informal Interpretations

8608013 Informal Interpretation

… Sharpe, Compliance Specialist Premerger Notification Office Bureau of Competition Federal Trade Commission 6th … of August 21, 1986. (Redacted) is negotiating to purchase the assets of a company in Florida which operates a number …
Date
Rule
801.1
[W]hat (redacted) collects in excess of receivables less reserve for bad debt will be for (redacted) account. (Redacted) has to guarantee the receivables. It sounds to me like (redacted) is acquiring...
HSR Informal Interpretations

8607011 Informal Interpretation

… Compliance Specialist Federal Trade Commission Premerger Office - Room 301 Washington, D.C. 20580 Dear Mr. Scanlon: … bank holding company acquisitions as described in the exemptions set forth in Subsections (7) and (8) of …
Date
Rule
7A(c)(7); 7A(c)(8)
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...
Advocacy Filings

FTC Staff Comment Before the Hawaii Office of the Auditor Concerning the Sunset Review of Statutory Provisions Prohibiting Certain Business Practices by Optometrists

… FTC Staff Comment Before the Hawaii Office of the Auditor Concerning the Sunset Review of Statutory …
Date
Matter Number
P864663
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