1810006 Informal Interpretation

1
Sheinberg, Samuel I.
From:
Sent: 	Monday, October 15, 2018 3:27 PM
To: 	Walsh, Kathryn E.; Berg, Karen E.; Carson, Timothy; Shaffer, Kristin; Sheinberg, Samuel I.
Subject: 	FW: Need for Refiling
From: Whitehead, Nora
Sent: Monday, October 15, 2018 3:27:05 PM (UTC-05:00) Eastern Time (US & Canada)
To:
Cc:
Subject: RE: Need for Refiling
No new filing would be required, under the circumstances you describe.
From:
Sent: Monday, October 15, 2018 3:01:44 PM (UTC-05:00) Eastern Time (US & Canada)
To:
Subject: Need for Refiling
Dear PNO Staff,
Is a new filing required if, after filing for an all‐cash acquisition, the parties agree to use buyer’s stock for part of the
consideration, but the seller’s acquisition of buyer’s stock is not reportable and the value of the reportable transaction
does not change? I believe the answer should be no new filing required, but I would be interested in your
thoughts. Thank you,
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