UPDATE January 9, 2017: This no longer represents the position of the PNO, see Informal Interpretation 17010004
Agree
Question
[redacted]
September 20, 2000
Mr. Michael Verne
Federal Trade Commission
Premerger Notification Office
600 Pennsylvania Avenue, N.W.
Washing ton, D.C. 20580
Re: 16 C.F.R. 802.9
Dear Mr. Verne :
This letter will confirm our telephone conversation of yesterday afternoon in which and I asked whether the collaboration efforts described in the attached sheet would render the "solely for the purpose of investment" exemption in 16 C.F.R. 802.9 inapplicable if one of the companies involved in the collaboration effortwere to buy voting securities of the other. You advised us that you consulted with Mr.Hancock of your office and that neither he nor you through the described collaborative efforts were inconsistent with, or would render inapplicable, the exemptions afforded by 16 C.F.R. 802.9.
We thank you for your assistance in this matter.
Sincerely,
[redacted]
cc: [redacted]