1. When I conduct a search, I found many informal interpretations on the same subject or I found two informal interpretations which contradict each other. Which informal interpretation is right?
As a general rule, start with the more recently written letters and work backwards in time. If a recent letter answers a particular question, that letter is most likely to be the current PNO position on that issue. If two letters contradict each other, the more recent of the two may be more likely to represent the current PNO position. If you have any questions, please contact the Premerger Office by email at hsrhelp@ftc.gov for clarification.
2. The searchable text version disagrees with the original scanned version. Which is correct?
Although all documents were proofread before being placed on the web page, the difficulty in reading some of the documents may have produced some transcription errors. If the writing is readable on the PDF version, that should supercede any contradictory language in the text version. Please report any discrepancies by email to hsrhelp@ftc.gov.
3. The PDF version is very difficult to read. Is there a better copy?
No. Many of the original documents are old and very difficult to read. We have tried to provide the best image available.
4. The redaction makes the informal interpretations incomprehensible. What do I do?
Unfortunately, many of the informal interpretations have been heavily redacted to prevent the revelation of confidential information. If an informal interpretation is redacted such that it is not useful, contact the Premerger Office by email at hsrhelp@ftc.gov for assistance.
5. Can I get an unredacted copy of the informal interpretation?
No. The confidential information contained in informal interpretations is protected under FOIA Exemption 3, 5 U.S.C. § 552 (b)(3) (citing Section 7A(h) of the Clayton Act, 15 U.S.C. § 18a(h) or Section 6(f) of the FTC Act, 15 U.S.C. §46(f)) or FOIA Exemption 4, 5 U.S.C. §552(b)(4).