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Agree. UPDATE March 23, 2015: The PNO’s current position is that where the primary acquisition is exempt under 802.51 or 802.52, any secondary acquisition (as defined in Section 801.4(a)) is also...
Agree that the initial steps do not require notification. At some point in the future, when enough of the working partners exchange their interests, (redacted) will acquire control of the (redacted)...
This should be analyzed as the formation of D under 801.40. D is not an acquiring person with respect to the X voting securities being contributed by A, B & C.