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Date

Tags:

Rule
6(c)
Staff
Nora Whitehead
Response/Comments

Confirmed.

Question

From: [Redacted]

Sent: Friday, December 01, 2017 9:13 AM

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

Sheinberg, Samuel I.; Whitehead, Nora

Subject: FW: Item 6(c)

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From: Whitehead, Nora

Sent: Friday, December 01, 2017 9:13:04 AM

To: [Redacted]

Cc: [Redacted]

Subject: RE: Item 6(c)

Auto forwarded by a Rule

Confirmed.

Nora Whitehead

(202) 326‐3262

From: HSRHelp

Sent: Thursday, November 30, 2017 3:23 PM

To: Walsh, Kathryn E.; Berg, Karen E.; Carson, Timothy; Gillis, Diana L.; Shaffer, Kristin; Sheinberg, Samuel I.;

Whitehead, Nora

Subject: FW: Item 6(c)

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From: [Redacted]

Sent: Thursday, November 30, 2017 3:23:21 PM

To: HSRHelp

Subject: Item 6(c)

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With respect to Item 6(c), can you confirm the advice provided in interpretations 1109021 and 1109007 – that identification of non‐US minority interests is only required if that non‐US entity earns revenue in the US (assuming an industry or NAICS code overlap) – is still the position of the PNO? https://www.ftc.gov/enforcement/premergernotification‐program/informal‐interpretations/1109021‐0 and https://www.ftc.gov/sites/default/files/documents/informal_interpretations/1109007‐informalinterpretation/1109007_0.pdf

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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