2501008 Informal Interpretation

Date

January 3, 2025

Rule

Item 7

Staff

Michelle Fetterman

Response/Comments

Yes, please include a note explaining that those establishments do not have street addresses.

Original Image - 2501008 Informal Interpretation (443.58 KB)

Question

From: Fetterman, Michelle
Sent: Friday, January 3, 2025 11:56:41 AM (UTC-05:00) Eastern Time (US & Canada)
To:[Redacted]
Cc: HSRHelp
Subject: RE: Request for HSR Assistance

Yes, please include a note explaining that those establishments do not have street addresses.

From: [Redacted]
Sent: Friday, January 3, 2025 10:39:36 AM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp
Subject: Request for HSR Assistance

Dear PNO,
I have a question regarding item 7(c) of the HSR form and would greatly appreciate your assistance.
I am representing a buyer that will be reporting an overlap under NAICS code 327320 (Ready-Mix Concrete Manufacturing). The instructions for 7(c)(iv)(b) say to “provide the address” of establishments that derived revenues under this code in the most recent year, organized by state, county, and city.
A handful of my client’s establishments that will be listed in item 7(c) do not have a street address. For example, these may be parcels of land within a large undeveloped or agricultural area that is owned by a third party.
For locations like these, in item 7(c), we can list the state, county, city, and instead of an address, we can provide section line information under the Public Land Survey System (e.g., N 1/2 SE 1/4 SW 1/4, S24, T32N, R18E). Does that work?

Sheinberg, Samuel I.
From: 	HSRHe lp
Sent: 	Friday, January 3, 2025 11 :57 AM
To: 	HSR Auto Forward List
Subject: 	FW: Request for HSR Ass istance
From: Fette rm an , Mich ell e
Sent: Fri da y, Jan uary 3, 2025 11:56:41 AM ( UTC-05:00) Eastern Ti me (US & Ca nada )
To:
Cc: HSRHe lp
Subject: RE: Req uest for HSR Assista nce
Ye s, pl ease in cl ude a note explaining that tho se establishments do not ha ve street addresses.
From :-
Sent: Fr ida y, Jan ua ry 3, 2025 10 :39:36 AM ( UTC -05:00) Ea stern Time ( US & Canada)
To: HSRHe lp
Subject: Request for HSR Assistance
Dear PNO ,
I ha ve a question regardi ng item 7(c) of the HSR form and would greatly appreciate yo ur as sistance.
I am represent ing a buyer that will be report ing an ov er lap und er NAICS code 327320 ( Read y-M ix Concrete
Manufacturing). The instruct ions for 7(c)(iv)(b) sa y to " provide the address" of estab li shments that d erived revenues
under th is code in the mo st recent year, organi zed by state , c ounty, and ci t y.
A handful of my cli ent's establis hment s that w ill be listed in item 7(c) do not ha ve a street addres s. For example, the se
may be parce ls of land with in a large undeveloped or agricultura l area that is owned by a th i rd party.
For loc at ions li ke the se, in item 7(c), we can list the state, count y, ci ty, and instead of an addre ss, we c an provide sect i on
line i nformat ion u nder the Pub lic Land Su rvey System (e.g., N 1/ 2 SE 1/ 4 SW 1/ 4, S24, T3 2N , R1 8E). Does that w or k?
Than ks in ad vance.
1

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2

2501008 Informal Interpretation

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