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… FTC Staff Comment to the National Association of Attorneys General Concerning Green Guides for Electricity Submitted by wfg-adm109 on … to the National Association of Attorneys General Concerning Green Guides for Electricity v980020.pdf Advocacy Filing …
… 9307006 Informal Interpretation 9307006 Informal Interpretation July 16, 1993 … At your request, I am writing this letter to describe the transaction that we discussed by phone today. The transaction summarized below involves my client (X) and …
Date
Rule
801.10(b) and (c)(2) and (3)
7/21/93 - The writer was advised that the PMN Offices response to question (1)is affirmative. In response to question (2), the grant of a non-exclusive trademarklicense need not be included in the...
… 9307007 Informal Interpretation 9307007 Informal Interpretation July … telephone conversation, I am writing this letter to request the views of the Premerger Notification Office regarding the … and the benefit of gain of the securities would be inthehands of the clients and they would be entitled to receive …
Date
Rule
801.1(c)
7/21/93 - called letter writer and advised that the Premerger Offices view is that the investment advisor does not hold the voting stock it acquires on behalf of its clients. (Also discussed possible...
… 9307003 Informal Interpretation 9307003 Informal Interpretation July 14, 1993 BY HAND Richard B. Smith, Esquire Premerger Notification Office … 20580 Dear Dick: As discussed, this letter will memorialize the additional views you expressed this morning over the …
Date
Rule
(limited liability company)
7/15/92 - called writer and left message that this letter corrects the incorrect advice given by me and reflected in the last paragraph on page 2 of the 7/13/93 letter. The letter of 7/6 and 7/13, as...
… 9306004 Informal Interpretation 9306004 Informal Interpretation June 17, 1993 … D.C. 20580 Dear Mr. Smith: This letter is to confirm the advice you gave the undersigned during a telephone conversation on …
Date
Rule
801.40; 802.20
7/9/93 called writer and advised that the conditional contributions and/or guarantees to be made to the joint venture if it is successful in its intended activities need not be counted into the assets...
… 9307002 Informal Interpretation 9307002 Informal Interpretation July 13, 1993 BY HAND Richard B. Smith, Esquire Premerger Notification Office … D.C. 20580 Dear Dick: I am writing to memorialize theinformal interpretations of the FTC Premerger …
… 9307004 Informal Interpretation 9307004 Informal Interpretation July 14, 1993 … Washington, D.C. 20580 Dear Patrick: This will confirm the details of the transaction I discussed with you this …
Date
Rule
802.9
I am not an attorney. This scenario is not exempt under Section 802.9. Trustees are comparable to officers or directors of a corporation. Therefore, the trustees of B becoming directors of A is...
… 9307005 Informal Interpretation 9307005 Informal Interpretation July 14, 1993 … acquired person in connection with a sale of fixed assets (the Assets) that are leased by one person to another …
Date
Rule
801.1(c) 801.2
Despite the fact that the leased assets are carried on the books of the lessee(redacted) (p.21), beneficial owership (sic) of the assets remains with the lessor(redacted). The (redacted) can buy the...
… 9307008 Informal Interpretation 9307008 Informal Interpretation July 20, 1993 … (redacted) for a case price of $20 Million. The REIT we represent (the Company) owns a portfolio consisting primarily of …
… 9306007 Informal Interpretation 9306007 Informal Interpretation June 29, 1993 … Washington, D.C. 20580 Re: Interpretation of "Solely for the Purpose of Investing Dear Mr. Hancock: We represent …
Date
7/1/93. Conclusion is OK. But only because they do not hold enough stock to elect the one director. If they could elect one by themselves, the transaction would not be exempt. T.F.H."
… 9307001 Informal Interpretation 9307001 Informal Interpretation July 6, 1993 By Hand Melea R. C. Epps, Esquire Richard B. Smith, Esquire … 20580 Dear Melea and Dick: In my recent discussions with the Premerger Notification Office concerning limited …
… 9306006 Informal Interpretation 9306006 Informal Interpretation June 28, 1993 … of Merger Scenario Dear Dick: I am writing to confirm the opinion you expressed in our telephone conversation today that the merger scenario set forth below should be treated as a …
Date
Rule
802.20, 7A(a)(3)(B)
6/29/93 - Advised writer that land and voting stock held by acquired person couldbe included as one transaction. Advised that Company A stock taken back byacquired person may also be reportable. He...
… 9306003 Informal Interpretation 9306003 Informal Interpretation By Telecopier … company Dear Sirs, We, (redacted), would like to know whether a premerger notification is required to file with your …
Date
Rule
802.20
(Redacted) called HDR on 6-18-93. Confirmed that figures in 2 are latest, andtotal holdings will be less than $15 mm. Exempt - 802.20 (b). HDR. RSconcurs.
… 9306005 Informal Interpretation 9306005 Informal Interpretation June 25, 1993 … for cash consideration of approximately $22,750,000. The (redacted) is currently held in a grantor trust … established by (redacted) and (redacted) in 1973. Under the terms of the trust, legal title is vested inthe Owner …
… 9306001 Informal Interpretation 9306001 Informal Interpretation VIA FEDERAL … Dear Ms. Epps: Confirming our discussion of June 1, 1993, the Federal Trade Commission has determined that our client, …
Date
Rule
801.1(b)
"(redacted) also indicated that the partnership has not acquired any new assets since (redacted) made the previous filing."
… 9306002 Informal Interpretation 9306002 Informal Interpretation June 15, 1993 … of this morning. I had asked your advice concerning the application of the requirement to make a notice filing pursuant to the …
Date
Rule
801.11
Spoke to (redacted). Agree with letter. No filing required.
… 9305012 Informal Interpretation 9305012 Informal Interpretation BY … our telephone conversation today during which we discussed the following hypothetical transaction. Two foreign limited partnerships, …
Date
Rule
802.50
June 93. Called (redacted) if (redacted) is in territorial waters of US, then it is a US asset. I (redacted) is reportable. RS agrees.
… FTC Staff Comment to the Honorable William F. Cass Concerning Massachusetts H.B. 1109 to Require Health Plans Offering Prescription Drug Services Contract with any Provider …
… 9305010 Informal Interpretation 9305010 Informal Interpretation May 24, 1993 … to confirm with you that it is your view that, based on the facts described below, our client has no obligation to …
Date
Rule
801.11
5-28 - Called (redacted) and also (redacted) (other side) and confirmed this is not reportable