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Dan Rosenthal
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Sep 14, 2026
Border Crossing: A Canadian Guide to U.S. Merger Enforcement
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32:24Dan RosenthalGUEST
well i mean look if you if you you read this to your children as a bedtime story like i do then then perhaps uh it's it's secondhand but uh no but uh Basically, this RFI is actually a very, very interesting RFI, given the timing of when the FTC issued this RFI, given the fact that there's an ongoing... legal dispute on appeal related to the HSR rules.
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32:53Dan RosenthalGUEST
But basically, what the RFI requested was for the public to provide commentary on the effectiveness of the expanded 2025 HSR rules, what they thought worked well, what they thought didn't work well.
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33:11Dan RosenthalGUEST
But also beyond that, they asked parties to weigh in and opine on certain structural questions related to the application of the HSR rules to specific types of transactions.
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33:33Dan RosenthalGUEST
That involves questions of whether certain exemptions to the HSR reporting requirements should be changed, should be revised.
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33:44Dan RosenthalGUEST
So in some ways, the RFI was a harbinger of maybe an understanding that there could be areas of improvement related to the expanded HSR rules.
11 MINS LATER