us-ftc-hsr-informal-interpretations-f45c8de987eb60437ef876f0830984eb•2409007 Informal Interpretation
2409007 Informal Interpretation
us-ftc-hsr-informal-interpretations-f45c8de987eb60437ef876f0830984eb2409007 Informal InterpretationGuidance
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 This e-mail is for the sole use of the intended recipient and contains information that may be privileged and/or confidential. If you are not an intended recipient, please notify the sender by return e-mail and delete this e-mail and any attachments. Certain required legal entity disclosures can be accessed on our website: https://www.thomsonreuters.com/en/resources/disclosures.html 1
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