1809001 Informal Interpretation

1
Sheinberg, Samuel I.
From:
Sent: 	Thursday, September 06, 2018 3:20 PM
To: 	Walsh, Kathryn E.; Berg, Karen E.; Carson, Timothy; Sheinberg, Samuel I.; Whitehead,
Nora
Subject: 	FW: 802.51
From: Shaffer, Kristin
Sent: Thursday, September 6, 2018 3:19:34 PM (UTC-05:00) Eastern Time (US & Canada)
To:
Cc: HSRHelp
Subject: RE: 802.51
Our views are still consistent with Interpretation #151 in the latest edition of the Premerger Notification Practice
Manual.
Best regards,
Kristin
Kristin Shaffer
Attorney
Premerger Notification Office
Federal Trade Commission
202‐326‐3434 | kshaffer@ftc.gov
From:
Sent: Thursday, September 06, 2018 10:36 AM
To:
Subject: 802.51
Dear HSR Team:
Are intercompany sales between or among the foreign parent and its U.S. subs or affiliates included in the total sales “in
or into the United States” under 802.51? I have a foggy memory that the PNO view on this issue might have changed,
but I cannot find a clear statement or anything in our notes here.
Thank you for your assistance.

2
________________________________
This email is for the use of the intended recipient(s) only. If you have received this email in error, please notify the sender immediately and then delete it. If you are
not the intended recipient, you must not keep, use, disclose, copy or distribute this email without the author's prior permission. We have taken precautions to
minimize the risk of transmitting software viruses, but we advise you to carry out your own virus checks on any attachment to this message. We cannot accept
liability for any loss or damage caused by software viruses. The information contained in this communication may be confidential and may be subject to the
attorney-client privilege. If you are the intended recipient and you do not wish to receive similar electronic messages from us in the future then please respond to
the sender to this effect.