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Date
Rule
802.51
Staff
Michael Verne
Response/Comments
Agree

Question

From: (redacted)

Sent: Thursday, December 01, 2005 1:36 PM

To: Verne,B. Michael

Subject: Questionre US sales

Hi Mike -

I have aquestion regarding US sales for an 802.51 analysis.

Target is an overseascompany with a controlled US subsidiary. The US subsidiary makes sales both in the US andto customers outside the US. I believe that only those sales tocustomers inside the US would count as US sales for 802.51 purposes. Seems to me the sales to customersoutside the US would be non-US sales, but please let meknow if I am incorrect.

About Informal Interpretations

Informal interpretations provide guidance from PNO staff on the applicability of the HSR rules to specific fact situations. They do not necessarily reflect the position of the Commission. 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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