2508002 Informal Interpretation

Our client is publicly launching a tender offer to acquire 100% of the voting securities of Target. The offer consideration consists of a mix of cash and stock, that is, a Target shareholder that tenders its Target shares to the offer will receive a fixed amount of cash and a fixed amount of stock per Target share. The cash portion of the tender offer will be 75% (well over 50%) of the voting securities of Target. Could you please confirm that our client can qualify for the 15-day waiting period? See interpretation https://www.ftc.gov/legal-library/browse/hsr-informal-interpretations/16110006.