2409007 Informal Interpretation

us-ftc-hsr-informal-interpretations-f45c8de987eb60437ef876f0830984eb2409007 Informal InterpretationGuidance

Date
Rule
Item 4
Staff
Vesselina Musick
Response/Comments

Confirmed.

Question

From: Musick, Vesselina <vmusick@ftc.gov>
Sent: Friday, September 13, 2024 3:47:11 PM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: HSRHelp <HSRHelp@ftc.gov>
Subject: RE: Question on 4(c) Documents

Confirmed.


From: [Redacted]
Sent: Friday, September 13, 2024 12:40:04 PM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp <HSRHelp@ftc.gov>
Subject: Question on 4(c) Documents

Hello!

I hope everyone is well. I had a question on Item 4(c). I wanted to confirm that the PNO’s current position is that documents that discuss only non-US markets (even if that portion of the transaction is exempt outside the US under Rules 802.50 and/or 802.51), must be submitted with the HSR filing.

I believe that is true based on the following:

https://www.ftc.gov/legal-library/browse/hsr-informal-interpretations/2305007

Sheinberg, Samuel I.
From: 	HSRHelp
Sent: 	Friday, September 13, 2024 3:47 PM
To: 	Walsh, Kathryn E.; Berg, Karen E.; Shaffer, Kristin; Sheinberg, Samuel I.; Six, Anne;
Whitehead, Nora; Fetterman, Michelle; Burton, June; Larson, Peter
Subject: 	FW: Question on 4(c) Documents
From: Musick, Vesselina <vmusick@ftc.gov>
Sent: Friday, September 13, 2024 3:47:11 PM (UTC-05:00) Eastern Time (US & Canada)
To:
Cc: HSRHelp <HSRHelp@ftc.gov>
Subject: RE: Question on 4(c) Documents
Confirmed.
From:
Sent: Friday, September 13, 2024 12:40:04 PM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp <HSRHelp@ftc.gov>
Subject: Question on 4(c) Documents
Hello!
I hope everyone is	well.	I had a question	on Item	4(c).	I wanted	to	confirm that the	PNO’s	current position is that
documents	that	discuss only non-US markets	(even if that portion of	the transaction is exempt outside the	US
under Rules	802.50 and/or 802.51), must be	submitted	with the	HSR filing.
I believe that	is true	based	on the following:
https://www.ftc.gov/legal-library/browse/hsr-informal-interpretations/2305007
Thanks	so	much!
Jen	Coon
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