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Federal Trade = Commission
Title: Notice=20 of Proposed Rulemaking
Subject=20 Category:=C2 16 CFR Parts 801, 802 and = 803=20 Premerger Notification; Reporting and Waiting Period = Requirements:=20 FTC Project No. P989316
Published: September 17, 2010 = View Notice (PDF) (Download Adobe Reader)
Comments Due: Monday, October = 18, 2010=20

Invitation To = Comment:
The=20 Federal Trade Commission seeks public comments on = proposed=C2 =20 amendments to the Hart-Scott-Rodino ("HSR") Premerger = Notification=20 Rules, the Premerger Notification and Report Form and = associated=20 Instructions in order to streamline the Form and capture new = information that will help the FTC and the Antitrust = Division of the=20 Department of Justice conduct their initial review of a = proposed=20 transaction=E2=80=99s competitive = impact.

Privacy & Use:
The FTC = Act and=20 other laws the Commission administers permit the collection = of=20 public comments to consider and use in this proceeding as=20 appropriate. All timely and responsive public comments, = whether=20 filed in paper or electronic form, will be considered by the = Commission, and will be placed on the public record of this=20 proceeding-including on the publicly accessible FTC website = at=20 http://www.ftc.gov/, to the extent = practicable.=20 Any information placed in the following fields on this form = --=20 "Title," "First Name," "Last Name," "Organization Name," = "State,"=20 "Postal Code," "Country," "Comments," and "Attachment" -- = will be=20 publicly available on the FTC Web site. Although filling out = this=20 comment form is voluntary, the fields marked with an = asterisk are=20 required in order for the FTC to fully consider a particular = comment. Because comments will be placed on the public = record=20 including on the publicly accessible FTC web site, they = should not=20 include any sensitive or confidential information. In = particular,=20 comments should not include any sensitive personal = information, such=20 as an individual's Social Security Number; date of birth; = driver's=20 license number or other state identification number, or = foreign=20 country equivalent; passport number; financial account = number; or=20 credit or debit card number. Comments also should not = include any=20 sensitive health information, such as medical records and = other=20 individually identifiable health information. In addition, = comments=20 should not include any "[t]rade secrets and commercial or = financial=20 information obtained from a person and privileged or = confidential. .=20 . .," as provided in Section 6(f) of the FTC Act, 15 U.S.C. = 46(f),=20 and Commission Rule 4.10(a)(2), 16 CFR 4.10(a)(2). Comments=20 containing material for which confidential treatment is = requested=20 must be filed in paper form, must be clearly labeled = "Confidential,"=20 and must comply with FTC Rule 4.9(c).¹ As a = matter of=20 discretion, the FTC makes every effort to remove home = contact=20 information for individuals from the public comments it = receives=20 before placing those comments on the FTC Web site. More = information,=20 including other routine uses permitted by the Privacy Act, = may be=20 found in the FTC's privacy policy, at http://www.ftc.gov/ftc/privac= y.htm.=20

Accessibility:
If you are = unable to=20 access this form, click=20 here for an alternate method of submitting a public = comment.=20

¹The comment must be accompanied by an = explicit=20 request for confidential treatment, including the factual = and legal=20 basis for the request, and must identify the specific = portions of=20 the comment to be withheld from the public record. The = request will=20 be granted or denied by the Commission's General Counsel, = consistent=20 with applicable law and the public interest. See FTC Rule = 4.9(c), 16=20 CFR 4.9(c).

Title:	First=20 Name:	*Last = Name:
Director, Section=20 of Antitrust Law	Joanne=20	Travis
Organization=20 Name:
American = Bar=20 Association
Mailing=20 Address:
321 N. = Clark=20 Street
City:	*State = Province:	Postal=20 Code:
Chicago	Illinois	60654
Country:
UNITED=20 STATES

Comments

Re:	Comments to =
Federal Trade Commission Regarding=20
        Proposed Amendments to the Hart-Scott-Rodino (HSR) Form

Dear Sir or Madam:

We are pleased to submit the attached comments on behalf of the Sections =
of Antitrust Law and International Law of the American Bar Association =
regarding the FTC=E2=80=99s proposed amendments to the Hart-Scott-Rodino =
Premerger Notification Rules, the Premerger Notification and Report Form =
and associated Instructions as reflected in the notice of proposed =
rulemaking issued by the Federal Trade Commission on August 13, 2010.

Please note that these views are being presented only on behalf of the =
Sections of Antitrust Law and International Law. They have not been =
approved by the House of Delegates or the Board of Governors of the =
American Bar Association and should not be construed as representing the =
policy of the American Bar Association.
If you have any questions after reviewing this report, we would be happy =
to provide further comments.

				Sincerely,
	=20
                                Allan Van Fleet
                                Chair, Section of Antitrust Law
	=20
                                Salli A. Swartz,
                                Chair, Section of International Law=20

Attachment

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Attached file: Comments - Joint = Comments=20 SAL SIL to FTC re HSR Form 9 22 10 FINAL = BA.pdf

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