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Called on 3/12. Left message stating that the letter accurately reflects our conversation and informal advice rendered. The acquisition appears to be part of a bona fide debt workout although the...

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HSR Informal Interpretations

9202010 Informal Interpretation

Date

March 5, 1992

Rule

802.20

Called (redacted) 3-5-92-- I agree with letter (since notes clear up some of the questions) RS concurs. What is the size of W. Corp? If less than $25MM in net sales and total assets then exempt under...

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HSR Informal Interpretations

9203001 Informal Interpretation

Date

March 1, 1992

Rule

7A(c)(8)

We may have some questions about whether this is exempt under c-8 or not. JS is discussing this with DOJ. Have exempted this under c-8 for this transaction only.// Per RS who indicated that JS ok'd...

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HSR Informal Interpretations

9203007 Informal Interpretation

Date

March 1, 1992

Rule

802.1

Industrial land such as an income producing warehouse will not be exempt even ifit is being sold to a developer of realty. The raw land is exempt and could bedeleted from the overall transaction to...

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HSR Informal Interpretations

9203010 Informal Interpretation

Date

March 1, 1992

Rule

7A(c)(3); 7A(c)(2); 801.14; 801.15; 802.30

801.14 - The assets must be aggregated with v/s of Sub. Z. Note: If asset purchase occurs first, do not aggregate. See example 801.14 and 801.13(b). Even if aggregated, value is less than $15 MM. (See...

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HSR Informal Interpretations

9203012 Informal Interpretation

Date

March 1, 1992

Rule

802.63(a)

Called on 3/31 to confirm that the letter reflects the advice provided. In an early conversation I explained that 802.63 was applicable even though A did not regularly lend money since the loan was...

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Advocacy Filings

FTC Staff Comment Before the New Hampshire Senate Legal Counsel Concerning H.B. 470 to Require any Health Maintenance Organization to Contract with any Pharmacy Meeting a Bid Accepted by the HMO for Pharmacy Preferred Providers

Date

March 1, 1992

Matter Number

V920010

FTC Staff Comment Before the New Hampshire Senate Legal Counsel Concerning H.B. 470 to Require any Health Maintenance Organization to Contract with any Pharmacy Meeting a Bid Accepted by the HMO for Pharmacy Preferred Providers (1.03 MB)

HSR Informal Interpretations

9202005 Informal Interpretation

Date

February 21, 1992

Rule

802.1(b); 801.15; 7A(c)(1)

2/21/92 - Advised (redacted) that the PMN Office was the view that the consideration paid for the six parcels of undeveloped land, i.e., $9.4 MM, could be excluded from the acquisition price under 801...

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HSR Informal Interpretations

9202006 Informal Interpretation

Date

February 21, 1992

Rule

7A(c)(1); 801.15; 801.10

2/21/92 Advised (redacted) that the PMN office was of the view that the $1MM paid for non-producing properties could, under § 801.15, be excluded from the acquisition price since, in our view, such...

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HSR Informal Interpretations

9202003 Informal Interpretation

Date

February 7, 1992

Rule

7A(c)(3)

I concur. PS. Called 2-7-92

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HSR Informal Interpretations

9202004 Informal Interpretation

Date

February 5, 1992

Rule

801.40; 802.60

2/5/92 - talked to (redacted). As to conclusion 2, pg 3., advised that, although underwriters are exempt under 802.60, if they are part of the formation of N, their contributions should be included in...

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HSR Informal Interpretations

9202001 Informal Interpretation

Date

February 1, 1992

Rule

7A(c)(1)

None

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HSR Informal Interpretations

9202002 Informal Interpretation

Date

February 1, 1992

Rule

801.2(a); 801.1(c)(1)

None

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HSR Informal Interpretations

9202007 Informal Interpretation

Date

February 1, 1992

Rule

7A(c)(1); 802.1(b)

The value of a contract transferred to another person where the contracted for product acquisition is exempt under 7A(c)(1) would be what is paid for the contract above and beyond any reimbursement of...

Original Image File (168.7 KB)

HSR Informal Interpretations