Tag: Competition

Displaying 1 - 20 of 95 results.

Filtering by content type: HSR Informal Interpretation

From: Gillis, Diana L.Sent: Friday, May 29, 2015 3:25 PMTo: (Redacted) Cc: Walsh, Kathryn E.Subject: RE: Question Regarding Distributions from Irrevocable Trusts(Redacted)(1) Distributions to settlor's spouse, rather than settlor, are not reversionary interests.(2) This also does not...
From: Walsh, Kathryn E.Sent: Tuesday, May 26, 2015 1:59 PM To: (Redacted)'; Berg, Karen E.Cc: Johnson, Janice C.; (Redacted); Gillis, Diana L; Whitehead, NoraSubject: RE: Issues under Sections 802.63(a), 801.15(a), and 802.9 affecting analysis of possible need for post-consummation...
From: Whitehead, NoraSent: Tuesday, May 26, 2015 2:52 PMTo: (Redacted),Cc: Walsh, Kathryn E.; Gillis, Diana L.Subject: RE: Ordinary Course Transaction
From: Gillis, Diana L.Sent: Monday, April 27, 2015 1:21PMTo: (Redacted); Walsh, Kathryn E.; Whitehead, NoraCc: (Redacted)Subject: RE: 802.9Hi (Redacted),The interpretation you cite is out of date. Where an individual is involved with a sub such that he could not claim passive intent...
From: Gillis, Diana L.Sent: Wednesday, May 13, 2015 2: 20 PMTo: (Redacted)Cc: Walsh, Kathryn E.Subject: RE: Rule 801.10 (Acquisition Price)Only a FMV can be relied on for 60 days. If the acquisition price in an asset deal cannot be determined before close, you simply rely on the FMV...
From: Gillis, Diana L.Sent: Monday, May 18, 2015 1:16PMTo: (Redacted); Walsh, Kathryn E.Subject: RE Your VMThe pullet houses are not exempt, because they are used in conjunction with the laying/washing/packing complex {it's an either/a( test- either adjacent to or used in conjunction...
From: Gillis, Diana L.Sent: Friday, May 22, 2015 8:57 AMTo: (Redacted),;Walsh, Kathryn E.Subject: RE :802.63 Exemption for an Acquisition of AssetsHi (Redacted),,All of the pre-petit on debt is exempt under 802.63. However, the post-petition debt (unless it is in fact reorganized pre...
From: (RedactedSent: Friday, May 22, 2015 2:49PMTo: Whitehead, NoraCc: Walsh, Kathryn E.; (Redacted),Subject: RE: CONFIDENTIAL TEATMENT REQUESTED RE: Informal Interpretation(Redacted),If you are able, do not report revenues in Item 5 that solely relate to the assets that are not...
 From: Whitehead, NoraSent: Monday, February 23, 2015 9:10 AMTo: (Redacted)Cc: Walsh, Kathryn E.; Berg, Karen E.; Gillis, Diana LSubject:  RE:4(d) questionYou are correct- you would not produce documents related to non-merger specific synergies. From: (Redacted)Sent: Friday, February...
From: Walsh, Kathryn E.Sent: Thursday, March 12 2015 1:43PMTo: (Redacted)Cc: Berg, Karen E.; Gillis, Diana L.; Whitehead, NoraSubject: RE: Pharma license questions
From: Gillis, Diana L.Sent: Tuesday, March 03, 2015 2:58PMTo: (Redacted)Cc: Walsh, Kathryn E.; Berg, Karen E.; Whitehead, NoraSubject:  RE: Question re: Voting TrustsWe analyze voting trusts like shareholder agreements or proxies. The 2014 interpretation you cite is on point, and...
From: Whitehead, NoraSent: Monday, February 23, 2015 9:10 AMTo: (Redacted)Cc: Walsh, Kathryn E.; Berg, Karen E.; Gillis, Diana LSubject:  RE: 4(d) question You are correct- you would not produce documents related to non-merger specific synergies. From: (Redacted)Sent: Friday,...
From: Whitehead, NoraSent: Friday, February 13, 2015 10:33 AMTo: (Redacted)Cc: Gillis, Diana L.; Walsh, Kathryn E.Subject: RE: HSR Question - Mortgage Origination Without the associated mortgages, the acquisition of the origination platform is not exempt under 7A(c}(2). From (...
From: Gillis, Diana LSent: Friday, February 06, 2015 9:35 AMTo:  (Redacted)Cc: Walsh, Kathryn E; Berg, Karen ESubject: RE New UPE QuestionThanks, (Redacted). Client X would not be able to rely on its Company A HSR. From: (Redacted)Sent: Thursday, February 05, 2015 2:47 PMTo: Gillis,...
From: Walsh, Kathryn E.Sent: Wednesday, January 28, 2015 9:42 AMTo: (Redacted)Cc: (Redacted), Subject: Berg, Karen E.; Gillis, Diana L.RE: HSR/size of person question(Redacted) - the PNO position is that once assets are listed on the balance sheet, there is little flexibility in the...
From: Gillis, Diana L. Sent: Friday, January 30, 2015 3:27 PM To: (Redacted) Cc: Walsh, Kathryn E.; Pope, Susan H.; Whitehead, Nora Subject: RE: 802.9 Quick Question We think being a director of target and officer of the PE firm that will be the GP of buyer precludes using the...
From: Walsh, Kathryn E. Sent: Friday, January 30, 2015 2:27 PM To: (Redacted) Cc: Gillis, Diana L.; (Redacted); Whitehead, Nora Subject: RE: HSR Valuation Question (Redacted), as we just discussed, Diana and I think you have to include the borrowed funds because Newco is a...
From: Pope, Susan H. Sent: Thursday, January 15, 2015 1:02 PM To: (Redacted) Cc: (Redacted), Walsh, Kathryn E.; Gillis, Diana l. Subject: FW: Item 5 Revenues for Insurance Operations Attachments: RE: Item 5 Revenue Reporting Confirmation (Redacted), Confirming our previous...
From: Verne, B. Michael Sent: Monday, December 29, 2014 2:23PM To: (Redacted) Cc: (Redacted), Walsh, Kathryn E. Subject: FW: Request for Guidance on Applicability of 15 USC 18a(c)(1) and 16 CFR 802.1 [ED-Ol.FID3414100] Subject: RE: Request for Guidance on Applicability of 15 USC...
From: Walsh, Kathryn E.Sent: Tuesday, December 30, 2014 3:10 PMTo: (Redacted)Subject: RE: quick queryRight. From: (Redacted)Sent: Tuesday, December 30, 2014 3:09PMTo: Walsh, Kathryn E.Subject: RE: quick queryThanks, Kate. Since it acts like an LP, does that mean that we would not...

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