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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:

About Informal Interpretations

Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

Learn more about Informal Interpretations.

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