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Date

Tags:

Rule
802.51
Staff
Kristin Shaffer
Response/Comments

Our views are still consistent with Interpretation #151 in the latest edition of the Premerger Notification and Practice Manual.

Question

From: Shaffer, Kristin


Sent: Thursday, September 6, 2018 3:19:34 PM (UTC-05:00) Eastern Time (US & Canada)


To: [Redacted]


Cc: [Redacted}


Subject: RE: 802.51

[Redacted]

Our views are still consistent with Interpretation #151 in the latest edition of the Premerger Notification Practice Manual.

Best regards,

Kristin

From: [Redacted}


Sent: Thursday, September 06, 2018 10:36 AM


To: [Redacted]


Subject: 802.51

Dear HSR Team:

Are intercompany sales between or among the foreign parent and its U.S. subs or affiliates included in the total sales “in or into the United States” under 802.51? I have a foggy memory that the PNO view on this issue might have changed, but I cannot find a clear statement or anything in our notes here.

Thank you for your assistance.

 

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