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Date
Rule
803.5
Staff
Premerger Notification Office
Response/Comments

What you propose for the affidavit is acceptable. If the letter of intent itself provides sufficient detail about the scope of the entire transaction, it is also acceptable to reference it alone (without the transaction diagram) in the affidavit.

Question

A client plans to submit an HSR filing for a transaction, which will be filed based on an executed letter of intent. The letter of intent is fairly fulsome; however, as the parties have negotiated the transaction they have also prepared a “transaction diagram” that provides additional details about the structure of the transaction. The buyer will be submitting the transaction diagram with its filing. The transaction diagram is a “dated document,” in that it reflects a specific date; however, the transaction diagram has not been separately executed by the parties.

My question is how we should handle this in the Affidavit. My thought was for the Affidavit to say something along the lines of “A Letter of Intent has been executed, pursuant to which ‘A’ will acquire 100% of the assets of ‘B.’ The Letter of Intent, in conjunction with the transaction diagram that is attached as Exhibit C-01, provides sufficient detail about the scope of the entire transaction that the parties intend to consummate.”

Does this work, or would you prefer that we handle this a different way?

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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