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Date
Rule
801.40, 801.11(e)
Staff
Analysis. XYZ Inc. will not own 100% of the LLC interests in XYZ LLC, nor will XYZLLC own 100% of the New LLC interests. Accordingly, neither the issuance of the Series Finterests in XYZ LLC to XYZ Inc. nor the contribution of the interests in New LLC by
Response/Comments
I concur with this letter. RS reviewed a prior draft. This letter is a final thataddresses most of RSs concerns - exceptions and clarifications are noted. 3/31/98PS

Question

XYZ 0.1% XYZ LLC 80.9 Other Investors 19.0

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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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