1603005 Informal Interpretation

us-ftc-hsr-informal-interpretations-e466b98117390c05b65deaab8173f82f1603005 Informal InterpretationGuidance

Date

Tags:

Rule
Items 3 and 4(b)
Staff
Evan Storm
Response/Comments

Do not need to translate documents reponsive to Items 3 or 4. If the agreement is in a foreign language, provide a thorough description of the transaction in Item 3(a). If the annual report is in a foreign language, provide the total assets and annual sales, or stipulate that size of person is met.

Question

[REDACTED]

It is acceptable to provide these documents as they are. For Item 3(a) please provide a thorough description of the transaction. For Item 4(b), since the annual reports are in Chinese include an endnote that either stipulates that the filer satisfies the size of person test, or provide the actual numbers for the filer’s total assets and total annual next sales.

Regards

Evan

Evan Storm

Attorney

Premerger Notification Office

Federal Trade Commission

(202) 326-3193

estorm@ftc.gov

HSR filing questions? Check the PNO Blog and HSR Tips.

From: [REDACTED]
Sent: Tuesday, March 22, 2016 10:44 AM
To: Storm, Evan
Subject: HSR Question

Evan:

I have a quick question. I am working on a foreign transaction that we will need to file an HSR Notification Report on. The Purchase Agreement and the Annual Reports are in Chinese. What is the protocol on this---do we have to obtain and provide English translations or can we just attach the Chinese versions.

Please let me know your thoughts.

Thanks,

[REDACTED]

From: 	Storm, Evan
To:
Subject: 	RE: HSR Question
Date: 	Tuesday, March 22, 2016 11:12:00 AM
Attachments: 	image001.png
It is acceptable to provide these documents as they are. For Item 3(a) please provide a thorough
description of the transaction. For Item 4(b), since the annual reports are in Chinese include an
endnote that either stipulates that the filer satisfies the size of person test, or provide the actual
numbers for the filer’s total assets and total annual next sales.
Regards
Evan
Evan Storm
Attorney
Premerger Notification Office
Federal Trade Commission
(202) 326-3193
estorm@ftc.gov
HSR filing questions? Check the PNO Blog and HSR Tips.
From:
Sent: Tuesday, March 22, 2016 10:44 AM
To: Storm, Evan
Subject: HSR Question
Evan:
I have a quick question. I am working on a foreign transaction that we will need to file an HSR
Notification Report on. The Purchase Agreement and the Annual Reports are in Chinese. What is
the protocol on this---do we have to obtain and provide English translations or can we just attach
the Chinese versions.
Please let me know your thoughts.
Thanks,
Complete printed PDF page 1

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