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Date
Rule
Form Item 5
Staff
Michael Verne
Response/Comments
Sales to Canadian and Mexican consumers would be included.

Question

From:

(redacted)

Sent:

Wednesday, August 20, 2008 11 :06 AM

To:

Verne, B. Michael

Subject: turnoverreporting

Hello Mike,

A non-urgentquestion for you to be answered whenever you can.

If a companymanufactures goods outside the US then books the goods through a US sub for sales to US, Canadian and Mexican customers, are the sales to the US customers only reported as wholesale revenues on the HSR Form, or would sales to theCanadian and Mexican customers count as well? I was not sure if the location ofthe customer affected this, and couldn't find guidance on the point.

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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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