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Date

Tags:

Rule
Item 1(f)
Staff
Karen Berg
Response/Comments

It should be 90% indirect ownership.

Question

From: [REDACTED]
Sent: Tuesday, April 12, 2016 2:07 PM
To: Berg, Karen E.
Subject: RE: Item 1(f)

 Thank you!

From: Berg, Karen E. [mailto:KBERG@ftc.gov]
Sent: Tuesday, April 12, 2016 2:05 PM
To: [REDACTED]
Subject: RE: Item 1(f)

Hi [REDACTED],

It should be 90% indirect ownership.

Karen

From: [REDACTED]
Sent: Tuesday, April 12, 2016 1:36 PM
To: Berg, Karen E.
Subject: Item 1(f)

Ms. Berg:

Our UPE owns 62% of a holding company, which owns 90% of our acquiring entity.  For Item 1(f), should the UPE’s indirect ownership of the acquiring entity be 56% (62 percent of 90 percent), or is it deemed to be a 90% holder?

Thank you,

[REDACTED]

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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