1610005 Informal Interpretation

From: Walsh, Kathryn E.
Sent: Wednesday, October 19, 2016 10:07 AM
To: [REDACTED]
Cc: [REDACTED]; Gillis, Diana L.
Subject: RE: Question on Item 8

Yes, it means your (1) below.

From: [REDACTED]
Sent: Tuesday, October 18, 2016 7:15 PM
To: Walsh, Kathryn E.
Cc: [REDACTED]
Subject: Question on Item 8

Dear Kate,

We would appreciate it if you could clarify one of the passages in the Item 8 instructions, namely: “This item pertains only to acquisitions of U.S. entities/assets and foreign entities/assets with sales in or into the U.S., i.e., with dollar revenues that would be reported in Item 5.”

Does “with sales in or into the U.S.” mean (1) at the time the Item 8 entity was acquired, or (2) sales that are being reported in the instant HSR that might be attributed to the entity/assets acquired in the past?

We presume that it means at the time of the original acquisition but would appreciate your confirmation on this point.

Best regards,

[REDACTED]