The Federal Trade Commission’s Premerger Notification Office (the “PNO”) is implementing a temporary e-filing system for Hart-Scott-Rodino (“HSR”) filing submissions in response to the developing COVID-19 pandemic. As of now, all hard copy and DVD submissions are suspended. Beginning Tuesday, March 17, at 8:30am, all HSR filings must be submitted via an online filing system. In addition, the PNO will not grant “early termination” of the statutory waiting period for any HSR filing for the duration of the use of the temporary e-filing system.
The procedure for electronic filings may be found here.
After the resumption of normal agency operations, all filing parties may have to submit hard copies or DVDs of filings made using the temporary e-filing system to both the PNO and the Department of Justice.
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If you have any questions concerning the foregoing, or HSR generally, please contact your Seward & Kissel relationship attorney.