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Date
Rule
801.15
Staff
Sam Sheinberg
Response/Comments

You are correct.

Question

You are correct.


From: [Redacted] 
Sent: Monday, March 6, 2023 5:05 PM
To: premerger <premerger@ftc.gov>
Subject: 801.15(a) query

Team,

I hope you are all doing well as spring approaches. Oddly enough, I have never confronted this issue before. In completing item 2(d) of the form, should the acquiring person include the percentage and value of shares that are not held pursuant to 801.15(a)? These shares are not included in calculating the transaction value, so it appears they should not be included in 2(d). Is this the PNO’s position?

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