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Date

Tags:

Rule
801.30, 803.12
Staff
Diana Gillis
Response/Comments

As long as the terms have not changed, a new notice letter is not necessary. The new affidavit can reference the original notice letter.

Question

From: Gillis, Diana L.

Sent: Thursday, June 29, 2017 1:44 PM

To: [Redacted]; Walsh, Kathryn E.; Berg, Karen E.; Carson, Timothy; Shaffer, Kristin;

Storm, Evan; Whitehead, Nora

Subject: RE: Pull-and-Refile Question

As long as the terms have not changed, a new notice letter is not necessary. The new affidavit can reference the original notice letter.

From: [Redacted]

Sent: Thursday, June 29, 2017 1:33 PM

To: Gillis, Diana L.; Walsh, Kathryn E.; Berg, Karen E.; Carson, Timothy; Shaffer, Kristin; Storm, Evan; Whitehead, Nora

Subject: Pull-and-Refile Question

Hello everyone,

If an acquiring person in a transaction subject to 16 C.F.R. 801.30 opts to pull‐and‐refile its HSR filing, does it need to resend notice to the acquired person who has already submitted its HSR filing? I did not see anything about this in the rules or PNPM or on the PNO’s website. If no new notice is required, should the new affidavit simply refer to the initial notice that was sent?

Thank you,

[Redacted]

About Informal Interpretations

Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

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