1302006 Informal Interpretation

Date

February 21, 2013

Rule

802.3

Staff

Michael Verne

Response/Comments

The relevant number is $200 million, so it is exempt under 802.3

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Question

From: (Redacted)

Sent:Tuesday, February 19, 2013 3:47

To:Verne, B. Michael(MVERNE@ftc.gov); Walsh, Kathryn(kwalsh@ftc.gov)

Subject: 802.3 Exemption

Hi Mike and Kate.

Company A plans to acquirea 1/3 interest in oil reserves for $200 million. Is this exempt under802.3 because it doesnot meet the $500 millionthreshold? Or is the relevant number the full value of the oil reserves ;e.g., $600 million?

Verne, B. Michael
From:
Sent :
To :
Subject:
Hi Make and Ka te,
Thursday, Fe bruary 21, 2013 9:06 AM
Verne, B. Michae l; Walsh, Kathryn
RE : 802.3 Exemption
Just checking back to see if you have had a chance to conside r my question.
Thanks
-F
Sent: Tuesday, February 19, 2013 3:47 PM
To: Verne, B. Michael (MYERNE@ftc.gov); Walsh, Kathryn (kwalsh@ftc. gov)
Subject: 802.3 Exemption
Hi M ik e and Kate.
Company A plans t o acq uire a 1 /3 i nterest in o il reserves for $200 m illion. 	Is this exem pt under 802.3 because it does
not meet t he $500 million t hreshold? Or is the relevant number t he f ull value of t he oi l reserves; e.g., $600 mi llio n?
Than ks
-
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The relevant number is $200 million, so it is exempt under 802.3

1302006 Informal Interpretation

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