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Legal Library: Search
The legal library gives you easy access to the FTC’s case information and other official legal, policy, and guidance documents.
… 9210001 Informal Interpretation 9210001 Informal Interpretation October 2, 1992 … the rules promulgated by the Federal Trade Commission (the FTC) under the Hart-Scott-Rodino Antitrust Improvements Act … me as soon as possible if I have incorrectly restated the FTC position on this matter. If you have any questions or …
… 9209009 Informal Interpretation 9209009 Informal Interpretation September 28, 1992 VIA FACSIMILE Richard B. Smith Premerger Notification Office Bureau of Competition Room 301 …
Date
Rule
802.20; 802.50; 801.90
10/6/92 Agreed with conclusion in letter. In hypothetical on page 2, the business justification for the spin off is that A only wants to purchase certain assets of subsidiary Y. The substance of the...
… 9210002 Informal Interpretation 9210002 Informal Interpretation October 5, 1992 VIA TELECOPY/OVERNIGHT MAIL Nancy Ovuka, Esq. Mail Stop: Rm. 301 Premerger Notification Office Bureau of Competition Federal …
Date
Rule
801.11(e)
10/6/92: I contacted (redacted) and informed him that if transaction is structured as Exhibit B, 801.11(e) is inapplicable for Step 2 and a filing would be required. NMO
… 9209010 Informal Interpretation 9209010 Informal Interpretation September 30, 1992 Patrick Sharpe, Esquire (PNO … below is reportable under the Hart-Scott-Rodino Antitrust Improvements Act of 1976, The Act, or whether it is, as we …
Date
Rule
802.1, 801.1(b), 801.1(c)
I have talked to both parties and have found that the warehouse is owned by a revocable trust. There are at least four settlors of the trust (including B) that are also the beneficiaries. Consequently...
… 9210004 Informal Interpretation 9210004 Informal Interpretation October 13, 1992 VIA HAND DELIVERY Victor L. … assume that no exemptions apply. I understand that the FTC would require A and B to report such a transaction under …
Date
Rule
801.40
For purposes of 801.40 analysis, the taking of an equity or membership interest in a limited liability company is tantamount to acquiring a voting security in a corporation. RS agrees with this...
… 9210009 Informal Interpretation 9210009 Informal Interpretation October 28, 1992 VIA FACSIMILE Victor Cohen, Esq. Premerger Office Federal Trade Commission Washington, D.C. …
Date
Rule
801.1(c)(1)
Acquisitions that are theoretically reportable in the instant letter in which third person (Corp. C) will file for acquisition need not be filed for by A and B due to applicability ofContinuum Theory...
… FTC Staff Response to the Hon. Robert J. Pavlovich Concerning Proposed Montana Legislation to Prevent Denturists From … Submitted by wfg-adm109 on October 1, 1992 | 12:00AM FTC Staff Response to the Hon. Robert J. Pavlovich …
… 9209004 Informal Interpretation 9209004 Informal Interpretation September 15, 1992 BY MESSENGER John M. Sipple, Jr., Esq. Premerger Notification Office Bureau of Competition Room 303 …
Date
Rule
7A(c)(4)
9/25 - Talked to the writer. Indicated that I concurred with his analysis that the acquisition of voting securities by B of As voting securities from LP1 was exempt under (c)(4).
… 9209007 Informal Interpretation 9209007 Informal Interpretation September 21, 1992 John M. Sipple, Jr., Esq. Assistant Director for the Premerger Notification Office Bureau of Competition Room 301 …
Date
Rule
801.11(b); 801.11(c)
9/25 Called and confirmed that this letter reflects the advice given; also confirmed that the financial statement of 1/3/192 is one of a series of such statements and that such statements are and have...
… 9209005 Informal Interpretation 9209005 Informal Interpretation September 15, 1992 BY OVERNIGHT COURIER John M. Sipple, Esquire Chief, Premerger Notification Office Bureau of Competition Federal …
Date
Rule
801.1(b)
Called on 9/23/92. Informed the writer that he was generally correct. However, I clarified that the partnership will be considered its own UPE, if prior to the transaction to acquire all the...
… 9209003 Informal Interpretation 9209003 Informal Interpretation September 9, 1992 Patrick Sharpe, Esquire [PNO … There is no suggestion that 16 C.F.R. 801.90 of the FTC Rules and Regulations is implicated. Based on the above …
Date
Rule
801.11(c)
Confirmed that total assets are less than $100 mm. This does not meet the size-of-person test. Called (redacted) 9-10-92.
… 9209002 Informal Interpretation 9209002 Informal Interpretation VIA FACSIMILE Mr. Patrick Sharpe Premerger … ordinary course of business.” 15 U.S.C. § 18a(c)(1). The FTC staff has long interpreted Section 7A(c)(1) to exempt …
Date
Rule
7A(c)(1)
This is an acquisition of rights in and to unproductive property and assets incidental to real property for $20 MM – exempt under (c)(1); called (redacted) 9-9-92; Tom Hancock and Richard Smith concur
… 9208011 Informal Interpretation 9208011 Informal Interpretation August 28, 1992 BY FAX: (202) 326-2050 Premerger Notification Office Room 303 Federal Trade …
Date
Rule
801.1(c)(1); 801.2(a); 801.10
Contacted (redacted). Informed him that we (including R Smith) agree with conclusion, specifically 1. actual adjusted price is the consideration 2. A is merely acting as an “agent” for C & D.
… 9208008 Informal Interpretation 9208008 Informal Interpretation August 26, 1992 VIA FEDERAL EXPRESS Patrick Sharpe Premerger Notification Office Bureau of …
Date
Rule
802.1; 801.10
I concur with this letter; call (redacted) 8-28-92
… 9208007 Informal Interpretation 9208007 Informal Interpretation August 25, 1992 BY HAND Mr. Patrick Sharpe Premerger Office Federal Trade Commission 6th St. and …
Date
Rule
801.1(c)
The Investment Advisor/Manager is the general partner of the three partnerships. Pursuant to the partnership agreements, the General Partner has what appears to be certain indicia of beneficial...
… 9208002 Informal Interpretation 9208002 Informal Interpretation BY FEDERAL EXPRESS John M. Sipple, Jr., Esq. Assistant Director Federal …
Date
Rule
802.64
8/19/92. Based on the fact scenario set forth in this letter, and the assumed correctness of the legal research, I advised (redacted) that John Sipple and I were of the view that Company X could...
… Beazer PLC, United States of America (For the FTC) Beazer PLC, United States of America (For the FTC) … Beazer PLC, United States of America (For the FTC) …