2208004 Informal Interpretation

From: Shaffer, Kristin <kshaffer@ftc.gov>
Sent: Friday, August 19, 2022 9:43:52 AM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: HSRHelp <HSRHelp@ftc.gov>
Subject: RE: Item 2(d) Disclosure

[Redacted]

Yes, a range may be provided so long as it does not straddle a fee threshold.

Best regards,

Kristin

From: [Redacted]
Sent: Friday, August 19, 2022 8:59:20 AM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp <HSRHelp@ftc.gov>
Subject: Item 2(d) Disclosure

Good Morning,

I hope this email finds you well. In an acquisition from an acquired person of 100% of its interests, is the acquired person required to disclose total aggregate value in Item 2(d) if it does not want the acquiring person to know that information and the acquiring person has disclosed that total aggregate amount in Item 2(d)? In other words, is a range sufficient so long as the stated range of value does not straddle a filing fee threshold?

Thanks in advance.