You should report the codes in Item 5, along with an explanation about the negative revenue, and Item 7 information if any of the codes capture overlaps.
Question
From: Walsh, Kathryn E. <kwalsh@ftc.gov>
Sent: Wednesday, November 15, 2023 9:12:47 AM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: HSRHelp <HSRHelp@ftc.gov>
Subject: FW: Item 5(a) Procedural Question
You should report the codes in Item 5, along with an explanation about the negative revenue, and Item 7 information if any of the codes capture overlaps.
From: [Redacted]
Sent: Monday, November 13, 2023 6:37:27 PM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp <HSRHelp@ftc.gov>
Cc: [Redacted]
Subject: Item 5(a) Procedural Question
I hope all is well. I am hoping the PNO team can help with a procedural question concerning Item 5(a). We are preparing a filing for a client which will list a number of NAICS and NAPCS Codes and corresponding revenue in Item 5(a).
I note that one of our client’s 6-digit nonmanufacturing codes and one 10-digit NAPCS Codes showed net negative sales. The negative net revenue was caused by a variety of reasons relating to sales.
Can I assume I do not have list NAICS Codes or NAPCS Codes that show net negative revenue in response to Item 5(a) or take these negative revenue codes into consideration when responding to Item 7 ?
As always, we appreciate Staff’s time and effort in assisting us.