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Date
Rule
Item 4
Staff
Vesselina Musick
Response/Comments

Confirmed.

Question

From: Musick, Vesselina <vmusick@ftc.gov>
Sent: Friday, September 13, 2024 3:47:11 PM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: HSRHelp <HSRHelp@ftc.gov>
Subject: RE: Question on 4(c) Documents

Confirmed.


From: [Redacted]
Sent: Friday, September 13, 2024 12:40:04 PM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp <HSRHelp@ftc.gov>
Subject: Question on 4(c) Documents

Hello!

I hope everyone is well. I had a question on Item 4(c). I wanted to confirm that the PNO’s current position is that documents that discuss only non-US markets (even if that portion of the transaction is exempt outside the US under Rules 802.50 and/or 802.51), must be submitted with the HSR filing.

I believe that is true based on the following:

https://www.ftc.gov/legal-library/browse/hsr-informal-interpretations/2305007

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. 

Learn more about Informal Interpretations.