Question
From:(redacted)
Sent:Friday, January 26, 2007 8:46 AM
To:Verne, B. Michael
Subject:Mike,
Mike,
Sorryfor the interruption. However, you have always been very helpful and Iappreciate your courtesy and assistance, both in the past and in anticipationof this instance as well. We have a potential HSR filing that we are looking atwhich involves two foreign issuers. We anticipate we will probably receivedocuments, in the form of financial statements and perhaps other kinds ofdocuments required to be attached under Item 4, that may be in a foreignlanguage. The only rule I have found that deals with when you have to interpretor translate foreign languages is Rule 803.8, which I understand basicallyprovides that if an English translation exists, then you need to provide boththe English translation and the foreign document with the exception being upona second request. I also found an informal interpretation that you hadpreviously given and I have attached that for your reference.
Question: Are there anyother rules that I have overlooked, or is my understanding correct, that if noEnglish translations of such documents exist, we can simply provide the foreigndocuments, but if we were to create any kind of summary to assist the FTC, orif that English document existed at the current time, then we would need toprovide both the English translation and the foreign document. If it is not toomuch trouble, I would just like you to confirm that my understanding iscorrect. Or, can you assist me by pointing me to other FTC guidance on how todeal with and file foreign documents?