1906008 Informal Interpretation

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Sheinberg, Samuel I.
From:
Sent: 	Wednesday, June 26, 2019 11:29 AM
To: 	Walsh, Kathryn E.; Berg, Karen E.; Carson, Timothy; Sheinberg, Samuel I.; Six, Anne;
Whitehead, Nora; Olson, Eric
Subject: 	FW: Items 5(a) and 4(c) Questions
From: Sheinberg, Samuel I. [mailto:SSHEINBERG@ftc.gov]
Sent: Wednesday, June 26, 2019 7:06 AM
To:
Cc:
Subject: RE: Items 5(a) and 4(c) Questions
Yes, you can allocate the revenue and please provide and endnote to explain. You are correct that this is still our
position with respect to text messages.
Sam Sheinberg
Attorney
Premerger Notification Office
From:
Sent: Tuesday, June 25, 2019 4:48:17 PM (UTC-05:00) Eastern Time (US & Canada)
To:
Cc:
Subject: Items 5(a) and 4(c) Questions

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Hi Everyone,
We have another couple quick HSR questions:
1. 	Our client breaks down revenue by source in its accounting software, but a small amount of its revenue was not
classified when entered and the company does not have a mechanism for tracking down which NAICS code it
would be associated with. This revenue would not be derived within a new/unique NAICS code, but rather
would be allocated amongst the existing codes that are being reported. Should we allocate this revenue
proportionately with the existing codes or take another approach? We would of course provide an endnote
explaining whichever methodology you would recommend.
2. 	Can you confirm that the attached guidance (that filers need not provide text message correspondence) is
current?
Thank you again for the assistance.