2110006 Informal Interpretation

She inberg, Samuel I.
From:
Se nt:
T o:
She inberg, Samuel I.
3AM
S ubj ect : 	RE: Item 5 and 7 q uestion
-Because the busi ness line was discontinued, rather than divested, report the revenue and add an endnote.
Sam
From: HSRHelp <HSRHelp@ftc.gov>
Se nt : Monday, October 4, 20219:16 AM
To: Walsh, Kathryn E.<kwa lsh@ftc.gov>; Berg, Ka r en E. <KB ERG@ftc.gov>; Sheinberg, Samuel I.
<SSHE INBERG@ftc.gov>; Six, Anne <asix@ftc.gov>; Wh itehead, Nora <nwhitehead@ftc.gov>; Musick, Vesse li na
<vmusick@ftc.gov>; Shaffer, Kr istin <kshaffer@ftc.gov>
Subject : FW: Item 5 and 7 question
From:
Sent : 	on ay, 	o er 	,
To: HSRHelp <HSRHelp@ftc.gov>
Subject: Ite m 5 and 7 question
Dea r PNO team :
I have, a hopefully, qu ick question on Item 5 and 7. The Acqui re d Person, Company A, d er ived revenue in its most recent
fiscal year-end in an overlapping NAICS code with the Acquiring Person. Company A has since discontinued the line of
business that der ives revenue in that overlapping code (not via a sale of the busi ness that reported that revenue, just
discontinued the line of business). Shou ld we still report in Item 5 and 7 but footnote that Company A no longer reports
revenue in that code or because it presently does not r eport revenue in that code we do not have to report the 2020
revenue at all.
Thanks very much for your guidance.
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