2207006 Informal Interpretation

Date

July 1, 2022

Rule

Item 7(c)(iv)

Staff

Vesselina Musick

Response/Comments

I am a PNO attorney and am writing to address your question below. Please create a separate attachment for the information in Item 7(c)(4)(a) as you propose. Please note that this will not be a "documentary attachment" as the term is defined in the instructions to the form (Page I), so it must be incorporated within the form and must not be submitted as a separate document. In practice that means that you will have to insert the attachment within the pdf form after the page with Item 7 information.

Kind regards.

Vesselina Musick

Original Image - 2207006 Informal Interpretation (199.59 KB)

Question

From: Musick, Vesselina <vmusick@ftc.gov>
Sent: Friday, July 1, 2022 2:46:26 PM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: HSRHelp <HSRHelp@ftc.gov>; Jones, Robert L. <RJONES@ftc.gov>
Subject: RE: Item 7(c)(iv)(a) - Question

Hello [Redacted]

Going forward, please email substantive questions such as this one to HSRHelp@ftc.gov instead of individual PNO attorneys.

Kind regards.

Vesselina Musick

Attorney | Federal Trade Commission | Premerger Notification Office

Direct +1 202.326.2307 | Email: vmusick@ftc.gov | www.ftc.gov

From: [Redacted]
Sent: Friday, July 1, 2022 2:01:43 PM
To: Jones, Robert L. <RJONES@ftc.gov>
Subject: Item 7(c)(iv)(a) - Question

Hi Robert,

I hope that you are well, today. I’ve got a question about how to complete Item 7(c)(iv)(a).

I believe that the form auto-populates the NAICs from Item 5(a) in Item 7(c)(iv)(a). It only adds one row for each code, and there seems to be a character limit in each row. However, I have over 200 locations to list by state, county, city, street address, and these will not all fit in one row.

How do I submit these? Should I create a new row for the locations that I can’t fit into a single row, or may I create an attachment and state “7(c)(iv)(a) See Attachment 7(c)(iv)(a) 448120”, for example?

Also, I had one other quick question. For addresses requiring states, when I try to select “GA” or put in “GA”, the form populates “FL”. Do you know what I may be doing wrong for these?

Any help will be most appreciated!

Sheinberg, Samuel I.
From: 	H SR Help
Sent: 	Friday, Ju ly 1, 2022 2:46 PM
To: 	Walsh, Kathryn E. ; Berg, Ka ren E. ; Shaffer, Kristin; She inber g, Samuel I.; Si x, Anne; Whi te head, Nora;
Fetterman, M iche ll e
Subject: 	FW : Item 7(c)(iv )( a) - Question
From: Musick, Vessel ina <vmusick@ftc.go v>
Se 	:00) Easte rn Time ( US & Ca n ada )
To:
Cc: 	o ert L. < RJONES @ftc.gov>
Subject: RE: Ite m 7(c)( iv)(a) - Quest ion
He ll o-
I am a PNO attorne y and am writ ing to address y our question below . Plea se create a separate attachment for the
i nformat ion in Item 7(c )( 4)(a) as you propo se. Please note that th is will not be a " documentary attachment " as the term
is defined in the i nstruct ions to the form (Page I), so it must be incorporated w i th in the form and must not be submi tte d
as a separate d ocument . In practice that means that y ou w ill have to insert the attachment wi th in the pdf form after the
page w i th Item 7 i nformat ion.
Going for w ard , please email substantive questions such as th is one to HSRHe lp@ftc.gov instead of i nd ividua l PNO
attorne y s.
Ki nd regards.
Vesselina Musick
Attorney I Federal Trade Commission I Premerger Notification Offi ce
Direct +1 202 .3 2 6 . 2307 I Email: vmusick@ftc.gov Iwww.ftc.gov
From:
Sent: Fr iday, July 1, 2022 2:01:43 PM
To: Jones, Robert L. <RJONES@ftc.gov>
Subject: Item 7(c )( iv )( a) - Questi on
Hi Robert,
I hope that y ou are w ell, toda y. I've got a questi on about how to compl ete Item 7(c )( iv)(a).
I believe that the form auto-popu lates the NAICs from Item S(a) in Item 7(c )( iv)(a). It only adds one ro w for each code,
and there seems to be a character lim it in each ro w. How ev er, I have ov er 200 locations to li st by state, count y, cit y,
street address, and these will not a ll fit in one ro w.
How do I submit these? Shou ld I create a new ro w for the locations that I can't fit i nto a single ro w, or may I create an
attachment and state " 7(c )( iv )( a) See Attachment 7(c )( iv)(a) 448120" , for example?
Also , I had one other qu ic k question. For addresses requiring states, when I try to se lect "GA" or put in " GA" , the form
populates " FL" . Do y ou know w hat I ma y be do ing w rong for these?
Any help w ill be most appreciated !
1

2207006 Informal Interpretation

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