0305009 Informal Interpretation

us-ftc-hsr-informal-interpretations-29ca1c1815dc4fb9bafac613a17849f60305009 Informal InterpretationGuidance

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Date

May 28, 2003

Rule

Item 4(c) Documents

Staff

Nancy Ovuka

Response/Comments

5/28/03 Only those portions for which privilege is claimed can be withheld. PNO has made one exception for Board Minutes. In that case, only the portion related to the transaction need be provided. This is not the case, here. In the instant transaction, the document involves a PowerPoint presentation where several topics are discussed. I advised writer that the entire presentations must be summated. NMO & MB concurs.

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Question

From:
Sent: Friday, May 23, 2003

To: Nancy M. Ovuka
Subject: 4(c) documents

Nancy, if you have a document have apportion of a 4(c) document, do you need to include the whole thing or can you just include the 4(c ) piece? I have a board package that covered 5 topics, only one of which related to the transaction. I would prefer not to include the other parts if I don't have to do so.

Much thanks.

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