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Date
Rule
801.1(j)
Staff
Michael Verne
Response/Comments
Yes the person is engaged in manufacturing. The $1MM limitation is worldwide.

Question

From:(redacted)
Sent:Monday, August 09, 2004 2:16 PM
To:Berg, Karen E.
Cc:Verne, B. Michael
Subject: Question

For purposes ofthe size-of-person test, is a person "engaged in manufacturing" ifthat person manufactures outside the United States more than $1 million worthof the types of products that, if they were manufactured in the U.S., wouldgenerate revenues that would be coded under NAICS 3133?

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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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