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Date
Rule
802.50, 802.51
Staff
Michael Verne
Response/Comments
Use the average exchange rate for the period.

Question

From:(redacted)
Sent.Wednesday, April 28, 2004 12:22 PM
To:Verne, B. Michael
Subject: Currencyconversion

Do you have an established procedurefor converting foreign currencies to dollars for purposes of applying rules802.50 and 802.51? Or can the party select any reasonable methodology fordetermining whether the sales in or into the US during a particular (typically one-year) period exceeded$50 million?

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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.

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