2109003 Informal Interpretation

Sheinberg, Samuel I.
From: 	HSRHelp
Sent: 	Tuesday, September 7, 2021 12:06 PM
To: 	Wa lsh, Kat hryn E. ; Berg, Karen E. ; She inberg, Samuel I.; Six, Anne; Whitehead, Nora; Musick, Vesse lina
Subject: 	FW: Question re UP E and 1(e) and 1(f)
From: Shaffer, Kr istin <kshaffe r@ ftc.gov>
Sent: Tuesday, September 7, 202112:05:58 PM (UTC-05:00) Easte rn Time ( US & Canada)
To:
Thank you for checking. You are correct that the Individual Person should be listed in Item s l (a) and 2(a) ( as well as 3(a )) .
-The Acquired Person should be lis ted in Item s l (f) and 3(a), as we ll as in Item l (e), if it is making the filing on behalf of
the Individual Person.
From:
Sent: Tuesda y, September 7, 2021 9:53 AM
To: HSRHe lp <HSRHelp@ftc.gov>
Cc:
Subject: Question re UPE and l (e) and l (f )
We are w or king on a pre not ification filing wi th respect to an asset acquisit ion where the Acquired Person is an LLC
including it s subsidi ar ies. The LLC is contro lled (70% membership interest) by an Individua l Person. Accordi ng ly, the
Individual Person is the UPE and will be the person fi ling in l (a) as well as 2(a ). If such is the ca se, we assume the
Acquired Person LLC will be li sted in l (e) and l (f ). Are our assumptions and i nterpretat ion correct? Your insight would be
greatly appreciated.
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