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1412004 Informal Interpretation
us-ftc-hsr-informal-interpretations-ecc320f4fe18f98bed1c809ff3e434151412004 Informal InterpretationGuidance
Date
Rule
Thresholds
Response/Comments
Correct - up to whatever the $500 million (as adjusted) will be at the time of the acquisition
Question
From: Verne, B. Michael
Sent: Wednesday, December 10, 2014 10:02 AM
To: (Redacted).; Walsh, Kathryn E.
Subject: RE: Thresholds
Correct- up to whatever the $500 million (as adjusted) will be at the time of the acquisition
From: (Redacted)
Sent: Wednesday, December 10, 2014 9:57AM
To: Walsh, Kathryn E.; Verne, B. Michael
Subject: Thresholds
Dear Kate and Mike:
It is my understanding that if X filed for the $141.8 million threshold in late 2013 and exceeded that threshold within a year of the expiration of the applicable waiting period, even if it did not hold shares meeting the increased threshold of $151.7 million, that its filing is effective and it has an additional 4 years to go up to but not hit the next threshold.
Do you agree?
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