1204011 Informal Interpretation

us-ftc-hsr-informal-interpretations-c16c4929d3d3858f63ab3b5fc1db9c101204011 Informal InterpretationGuidance

Date
Rule
801.11(e), 801.1(a)(2)
Staff
Michael Verne
Response/Comments
Agree.

Question

From: (redacted)
Sent: Monday, April 23, 2012 2:55 PM
To: Verne, B. Michael
Subject: Further Question

Iwas thinking further about our exchange this morning about an LLC owned by afederally recognized Indian tribe being an "entity" within the HSRdefinition although the Indian tribe itself would not fall within theexemption. I don't see anything precluding the LLC, being newly established,relying on 801.11(e) in its first acquisition when it does not have a balancesheet. Do you agree?


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