us-ftc-hsr-informal-interpretations-5614586d4404bfd9ab5155e29184345e•2508004 Informal Interpretation
2508004 Informal Interpretation
us-ftc-hsr-informal-interpretations-5614586d4404bfd9ab5155e29184345e2508004 Informal InterpretationGuidance
Thank you for checking. Rather than include a separate attachment, please submit the information as extra pages inserted into the Form (using the same format as the table in the Form). Please note that only the top-level acquired entities need to be listed as targets in the Transaction Information section. That is, if some of the entities are controlled by other targets, these subsidiary entities do not need to be listed there. They should, however, be listed under the Acquired Entity Structure section.
Question
I am preparing an HSR filing for an acquired person where a long list of “targets” are relevant for purposes of the “Parties” subheading under “Transaction Information.” Rather than add numerous additional rows to the box, I plan to include an attachment providing the name and required information for these target entities. Because the HSR Filing Attachment Reference does not identify a letter prefix for this situation as it does for other particular types of attachments, I plan to label it simply “Attachment 1” and state “See Attachment 1” under “Target(s)” on the form. Can you confirm that this is acceptable? If not, please advise how the attachment should be labeled.
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