Pre-Merger Notification Guide: Canada’s Competition Act
Contents
Canada's Pre-Merger Notification Regime
01
Determining Whether a Transaction Is Notifiable
02
Step 1: Assess the Transaction-Size Threshold Step 2: Assess the Party-Size Threshold
02 04 04
Step 3: Evaluate Possible Exemptions
Notification and Clearance
06
Timelines for Notification and Clearance
08
Merger Enforcement Trends
10
Selected Resources
11
Definitions
12
Key Contacts
14
Canada's Pre-Merger Notification Regime Canada's Competition Act provides that certain types of transactions (Notifiable Transactions) exceeding monetary and other thresholds – referred to as “party- size” and “transaction-size” thresholds – must be notified to the Commissioner of Competition (Commissioner), who is the head of the Competition Bureau (Bureau), prior to closing. In the absence of an exemption or a waiver, parties to Notifiable Transactions must provide the Commissioner with prescribed information and comply with a specified waiting period before completing the transaction. Parties that have completed a Notifiable Transaction without complying with these provisions may have committed a criminal offence and be liable for significant fines and court-ordered remedies, including dissolution of the transaction. It is important to note that, irrespective of size, all acquisitions of control or of a significant interest in the business of another entity with a real and substantial connection to Canada may be subject to review and possible challenge by the Commissioner for up to three years after closing if the Commissioner finds that the merger is likely to prevent or lessen competition substantially. Only the Commissioner can commence a challenge under the merger provisions of the Act. Applications by the Commissioner are heard by the Competition Tribunal, which is a quasi-judicial body comprising lay and judicial members. The Commissioner actively monitors media reports for non-notified mergers; therefore, parties to such proposed acquisitions should consult competition law experts early in the process to minimize the risk of unforeseen consequences. This step-by-step guide is designed to assist with determining whether a proposed transaction is subject to mandatory pre-merger notification in Canada. All amounts are expressed in Canadian dollars and are based on audited financial statements for the most recent fiscal year – for example, asset values refer to book value reported in audited financial statements, not fair market value. (Monetary amounts referenced in this guide are current as of April 1, 2026.)
1
Pre-Merger Notification Guide
Determining Whether a Transaction Is Notifiable
The Act contemplates five broad categories of transactions that are subject to pre-merger notification (listed below). Each category requires that the target has an “operating business” in Canada, defined as a business undertaking in Canada to which employees employed in connection with the undertaking ordinarily report for work. Step 1: Assess the Transaction-Size Threshold
If there is an “operating business” in Canada, does the proposed transaction exceed the applicable transaction-size threshold on the basis of the relevant transaction type below?
2. Share Acquisition
1. Asset Acquisition
Does either (i) the value of the target’s assets in Canada or (ii) its annual gross revenues from sales in, from or into Canada generated from those assets exceed $93 million? and
Does either (i) the value of the target’s assets in Canada or (ii) its annual gross revenues from sales in, from or into Canada generated from those assets exceed $93 million? Gross revenues “in, from or into” Canada refers to domestic sales, export sales to a foreign jurisdiction and import sales from a foreign jurisdiction.
Where any of the target’s voting shares are publicly traded, will the purchaser and its affiliates own more than a 20% voting interest following the acquisition if more than a 20% but less than a majority voting interest is already held, will the purchaser and its affiliates own more than a 50% voting interest following the acquisition?
Where none of the target’s voting shares are publicly traded, will the purchaser and its affiliates own more than a 35% voting interest following the acquisition if more than a 35% but less than a majority voting interest is already held, will the purchaser and its affiliates own more than a 50% voting interest following the acquisition?
or
2
Davies | dwpv.com
3. Amalgamation
4. Formation of
5. Acquisition of an Interest in an Unincorporated Combination Does either (i) the value of the unincorporated combination’s assets in Canada or (ii) its annual gross revenues from sales in, from or into Canada generated from those assets exceed $93 million?
Unincorporated Combination
Does either (i) the value of the continuing corporation’s assets in Canada or (ii) its annual gross revenues from sales in, from or into Canada generated from those assets exceed $93 million?
Does either (i) the value of assets of the combination in Canada or (ii) the annual gross revenues from sales in, from or into Canada generated from those assets exceed $93 million? Note that for purposes of the pre-merger notification requirements, a combination includes a partnership, trust or any other form of non-corporate entity or association.
and
Do at least two of the amalgamating corporations,
and
together with their affiliates, each have either (i) assets in Canada or (ii) annual gross revenues from sales in, from or into Canada, with a value in excess of $93 million? Note that for purposes of the pre- merger notification requirements, a Delaware merger (also known as a triangular merger), including a reverse Delaware merger, is considered to be an amalgamation.
Will the purchaser and its affiliates be entitled to more than 35% of either the profits or the assets on dissolution or if more than a 35% but less than a majority interest is already held by them, will they be entitled to more than 50% of either the profits or the assets on dissolution?
If the applicable transaction-size threshold is not exceeded, pre-merger notification is not mandatory , even if the parties meet the party-size threshold.
If yes, proceed to Step 2 to assess the party-size threshold.
3
Pre-Merger Notification Guide
Determining Whether a Transaction Is Notifiable (Cont'd)
Step 2: Assess the Party-Size Threshold
Step 3: Evaluate Possible Exemptions A transaction that satisfies both of the above thresholds may not be subject to pre-merger notification if it falls within a statutory exemption. Do any of the exemptions below apply in respect of the proposed transaction? This is not an exhaustive list and other exemptions may be available. The Commissioner may also waive the requirement to pre-notify where satisfied that the proposed transaction is not likely to prevent or lessen competition substantially.
Do the parties to the transaction together with their affiliates collectively have either
(i) assets in Canada
or
(ii) gross revenues from sales in, from or into Canada in excess of $400 million? Gross revenues “in, from or into” Canada refers to domestic sales, export sales to a foreign jurisdiction and import sales from a foreign jurisdiction.
1. Transaction Among Affiliates
An acquisition is exempt if all parties to the transaction are affiliates of each other. (For this purpose, the “parties” to a share acquisition are the acquirer of the shares and the corporation whose shares are to be acquired.)
2. Acquisition of Real Property or Goods in the Ordinary Course of Business
An acquisition of real property or goods in the ordinary course of business is exempt if the purchaser would not, as a result of the acquisition, hold all or substantially all of the assets of a business or of an operating segment of a business. The Bureau considers that certain intangible assets such as loans, mortgages and receivables may be “goods” for the purpose of this exemption. Guidance from the Bureau takes the position that, in some cases, each location of a company’s business may be viewed as a business or an operating segment of a business.
If the proposed transaction exceeds the party-size threshold, it is notifiable subject to any exemption or waiver that may apply. Proceed to Step 3 .
If not, pre-merger notification is not mandatory.
4
Davies | dwpv.com
3. Realization on Credit Transaction Entered in the Ordinary Course of Business An acquisition of collateral or receivables or an acquisition resulting from foreclosure or default or forming part of a debt workout is exempt if made by a creditor in or pursuant to a credit transaction entered into in good faith in the ordinary course of business.
4. Certain Non-Corporate Joint Ventures
5. Canadian Resource Property
A non-corporate joint venture is exempt if it meets the following three-part test: i. all the proposed parties to the joint venture are parties to an agreement in writing (or intended to be put in writing) that requires one or more of them to contribute assets and governs a continuing relationship between them; ii. no change in control over any party to the joint venture would result from the formation of the joint venture; and iii. the joint venture agreement restricts the range of activities that may be carried on by the
An acquisition of a “Canadian resource property” (as defined in subsection 66(15) of the Canadian Income Tax Act ) is exempt if, as a condition of the transfer, the acquirer agrees to incur expenses to carry out exploration or development activities with respect to the property, subject to certain conditions. A similar exemption applies to an acquisition of equity interests in an entity under an agreement in writing that provides for the creation of those equity interests only if the persons acquiring them incur expenses to carry out exploration of, or development activities regarding, a Canadian resource property, in respect of which the entity has the right to carry out those activities (provided that the entity does not have any significant assets other than that resource property).
joint venture and contains provisions that allow for its orderly termination.
The Bureau takes the view that this exemption does not apply to joint ventures in a corporate form.
If no exemption applies, the proposed transaction is subject to mandatory pre-notification. Proceed to the following section for guidance on notification and clearance.
If any of the exemptions above apply, pre-merger notification is not mandatory .
Caveat: If a transaction is designed to avoid the application of the pre-merger notification provisions, the provisions will apply to the substance of the transaction. This anti-avoidance provision was added to the Competition Act in 2022, but has yet to be applied by the Bureau or interpreted by the Tribunal.
5
Pre-Merger Notification Guide
Notification and Clearance If a proposed transaction exceeds the notification thresholds and does not fall within a statutory exemption, parties may either give the requisite notice or obtain from the Commissioner an exemption from or a waiver of the notification obligation that also provides comfort that the Commissioner will not challenge the transaction. Depending on the extent to which a proposed Notifiable Transaction may raise potential competition issues, parties typically file a request for an Advance Ruling Certificate (ARC) or, alternatively, a no-action letter (NAL), either in lieu of or in addition to filing a formal notification with the Bureau. These types of filings are discussed below. Further, even if pre-notification is not mandatory, parties sometimes notify the Commissioner voluntarily to obtain greater certainty that the transaction will not be challenged, particularly in cases in which the proposed transaction may result in significant horizontal or vertical competitive overlaps. As noted above, the Commissioner can challenge any transaction for up to three years after closing. Regardless of the type of filing(s) made with the Bureau, a filing fee, currently $90,198.19, is payable for each transaction for which the parties request clearance and/or file a notification, regardless of the transaction size.
Apply for an Advance Ruling Certificate or a No-Action Letter Most commonly, to facilitate the Bureau’s review, parties file a submission or “white paper” analyzing the substantive competitive effects of the proposed transaction and requesting an ARC or a NAL, although such a request does not in itself trigger the start of a statutory waiting period. The filing of the submission may, however, trigger the application of the non-binding service standard periods discussed below. Such a submission typically addresses the degree of competitive overlap between the acquirer and the target, their respective market shares, other competitors in the market, potential for expansion or entry by other competitors, countervailing power of customers or suppliers, and other factors relevant to whether the proposed transaction is likely to result in higher prices or otherwise enhance market power in any market in Canada. An ARC is typically issued only for mergers with no or minimal competitive overlap between the parties. An ARC effectively precludes the Commissioner from challenging the transaction so long as the transaction is completed within one year. A NAL states that the Commissioner does not currently intend to make an application challenging the transaction (but reserves the right to do so for up to one year after closing). A NAL can also include a waiver of the notification requirement. Parties routinely close transactions in reliance on a NAL.
6
Davies | dwpv.com
File a Notification Form Parties may also file prescribed information to start the statutory waiting periods discussed below. Each party is required to certify that the information it has supplied is correct and complete in all material respects. A template notification form is available on the Bureau’s website. Parties may elect not to provide certain information – for example, in cases where it is privileged, not reasonably obtainable, not known or not relevant to the Commissioner’s review of the proposed transaction; however, the Commissioner can, on the basis of relevance, require the submission of information initially withheld. The Merger Intelligence and Notification Unit of the Bureau is responsible for handling all merger notifications.
7
Pre-Merger Notification Guide
Timelines for Notification and Clearance
Statutory Waiting Periods for Notifiable Transactions The initial statutory waiting or no-close period is 30 days from receipt of a complete notification from each party to the transaction (except in the case of an unsolicited share acquisition, in which the waiting period commences upon receipt of a complete notification from the purchaser). In circumstances in which the Bureau requires additional information to complete its review, the Commissioner may issue a supplementary information request (SIR) prior to expiry of the initial 30-day waiting period, in which case the transaction cannot be completed until 30 days after each party certifies compliance with the SIR. After the second 30-day period has elapsed, the parties may complete the transaction unless the Commissioner obtains an injunction from the Competition Tribunal. When the Commissioner exercises his or her discretion to issue a SIR, the Bureau will generally provide a draft SIR and engage in limited pre-issuance dialogue with each recipient party. SIRs can require extensive document (including electronic records) and data production, and a complete response can take many weeks. In some cases, the Bureau will continue its investigation beyond the expiration of the initial waiting period without issuing a SIR but enter into a “timing agreement” with the parties to address key milestones, such as commitments regarding the earliest closing of the proposed transaction and possible further production requirements. Such timing agreements may also be entered into following expiry of the waiting period 30 days after compliance with a SIR.
NOTIFICATION AND CLEARANCE TIMELINES
Clearance – Expiry of waiting period
– ARC – NAL
Clearance – Expiry of waiting period – NAL
Filing of Notification (with or without request for ARC or NAL)
30-day waiting period
New 30-day waiting period
Issuance of SIR (prohibited from closing)
Compliance with SIR
Application to challenge (may also seek interim order)
8
Davies | dwpv.com
Note that the Commissioner can issue a NAL or waiver exempting the parties from further compliance with the waiting periods at any time during the process, effectively providing clearance for the proposed transaction.
These service standard periods are (i) 14 days for non-complex mergers (transactions that clearly have no competition issues because there is minimal or no competitive overlap between the merging parties) and (ii) 45 days for complex mergers (transactions between competitors, or a customer and supplier, where there are indications that the transaction may create, maintain or enhance market power). The service standard periods start to run once the Bureau determines that it has all the information necessary from the parties to commence its analysis. The periods can be suspended and restarted if the Bureau considers that a party is not responding to Bureau questions in a timely manner. The service standard periods are not binding, and actual timing of the Bureau’s review of a proposed transaction can also be influenced by many factors, including other mandatory regulatory review processes (e.g., reviews under the Investment Canada Act for certain investments in Canada by non-Canadians; see Davies’ ICA Guide for more details) or reviews of the same transaction in foreign jurisdictions.
Unsolicited Takeover Bids Where only a bidding party (and not the target company) files a notification, the Commissioner is required to notify the target company immediately, and the target is then required to file its portion of the notification within 10 days. The timing of the target’s filing of either an initial notification or responses to a SIR does not affect the running of either the initial waiting period or the waiting period following the bidding party’s response to a SIR.
Service Standards for ARCs and NALs The Bureau has established a non-binding
classification system for proposed mergers and associated “service standard” timelines within which it aims to complete its competitive assessment of the merger. (These service standards are distinct from and do not affect the above-noted statutory waiting periods.)
9
Pre-Merger Notification Guide
Merger Enforcement Trends Although most mergers that raise competition issues are resolved by a consent agreement between the parties and the Commissioner (typically requiring
The recent amendments repealed a statutory efficiencies defence for mergers. Relatively few mergers had proceeded in reliance on that formal efficiencies defence. Recent Bureau guidance recognizes that pro competitive benefits could still be one consideration, among others, in the overall competitive effects analysis. Likely and verifiable merger-specific, rivalry-enhancing pro-competitive benefits (such as cost savings that directly intensify competition or consumer-facing improvements) should be relevant, but some Bureau guidance conveys a skepticism of, or hesitancy to give full weight to, a merger's pro-competitive benefits where a merger raises substantial competition concerns. Whether the Tribunal will share this perspective remains to be seen. Where the Tribunal finds that a merger is likely to result in a substantial lessening or prevention of competition, the Act now provides that the Tribunal may make an order “to preserve the level of competition” that would prevail “but for the merger.” Prior court decisions had established that the objective of an order under the merger provisions was to restore competition to the point at which it is no longer substantially less than it was before the merger. The Commissioner long advocated for this amendment with a view to reducing the burden to obtain more extensive remedies or blocking altogether a merger found to prevent or lessen competition substantially. However, it remains to be seen how the Tribunal will assess the “level of competition” in this context. The Tribunal also retains discretion with respect to the issuance of orders – even where a merger is found to result in a substantial prevention or lessening of competition. Nevertheless, this amendment and any resulting difference between the standard to block a merger (or an aspect of it) and the remedy that may be required to preserve competition may lead parties to restructure and then refile their transaction or be more inclined to propose remedies up front.
divestiture of some businesses or assets), the Commissioner continues to be prepared to litigate merger challenges before the Tribunal. Significant amendments to the Competition Act enacted from 2022 to 2024 designed to make it easier for the Commissioner to challenge mergers have created some uncertainty in the Canadian merger review process. Perhaps most significantly, the Act now provides that mergers will be presumed to prevent or lessen competition substantially if they (a) (i) combine firms with more than a 30% aggregate market share; or (ii) result in a post-merger "concentration index" of more than 1,800 (determined by squaring the market shares of the participants in the relevant market); and (b) result in an increase in the concentration index of more than 100 from pre-merger levels. The presumption would, for example, be triggered if a firm with a 30% share acquired a firm with a 2% share of a properly defined market, or if a firm with a 16% share merged with a firm with a 15% share. Similarly, depending on the number of other competitors and their market shares, a merger of two firms with market shares of 7% and 8%, respectively, could potentially also trigger the presumption. In considering whether parties to a merger have rebutted such a presumption, Bureau guidance to date indicates that it will apply a sliding scale: the more the thresholds are exceeded, the greater the need for "persuasive evidence" to overcome the presumption. For example, evidence of effective remaining competition, likely timely and sufficient entry, and other market-specific constraints on any potential exercise of market power by the merged firm may help to rebut the presumption. Although the Bureau has not provided details of its analyses, it appears to have been issuing NALs for mergers that exceeded the Act’s concentration threshold.
10
Davies | dwpv.com
SELECTED RESOURCES
1. Competition Act (Canada), RSC 1985, c C-34 T he Act is a federal statute governing the general regulation of trade and commerce in respect of conspiracies, trade practices and mergers affecting competition in Canada. Sections 91–99 address the substantive review of mergers. Sections 108–124 set out the requirements for pre-merger notification. 2. Notifiable Transactions Regulations , SOR/87-348 T hese regulations are made under the Act and, among other things, set out procedures for calculating the aggregate value of assets and gross revenues from sales for purposes of the party-size and transaction-size thresholds for the pre-merger notification provisions in the Act. 3. Pre-Merger Notification Interpretation Guidelines (various) T he Commissioner issued these interpretation guidelines to assist parties with interpreting and applying certain provisions of the Act and regulations relating to notifiable transactions, including with respect to defined terms, exemptions and transaction structures 4. Procedures Guide for Notifiable Transactions and Advance Ruling Certificates Under the Competition Act (November 1, 2010) T his guide provides an overview of provisions of the Act and regulations and explains Bureau procedures relating to notifiable transactions and advance ruling certificates. 5. Competition Bureau Fees and Service Standards Handbook for Mergers and Merger‑Related Matters (May 1, 2018) T his handbook provides information related to the Bureau’s fees, complexity designations, service standard periods and procedures for mergers and merger‑related matters. 6. Merger Review Process Guidelines (September 8, 2015) T hese guidelines describe the Bureau’s general approach to administering the Act’s two-stage merger review process, including determining whether to issue a SIR, working with merging parties to narrow issues and/or SIR requirements for records, including data, and considering whether a timing agreement is appropriate. 7. Merger Enforcement Guidelines (October 6, 2011) and Proposed Merger Enforcement Guidelines (November 13, 2025) T hese guidelines provide general direction on the Bureau’s analytical approach to assessing whether a merger is likely to prevent or lessen competition substantially, including the Bureau’s approach to market definition, the significance of market shares and the assessment of different types of potential anticompetitive effects. 8. Information Bulletin on Merger Remedies in Canada (September 22, 2006) T his bulletin sets out the Bureau’s policy on merger remedies, including providing guidance on the objectives for remedial action and the general principles applied by the Bureau when it seeks, designs and implements remedies.
11
Pre-Merger Notification Guide
Definitions
Audited Financial Statements When audited financials for the most recently completed fiscal year are not available, calculations are based on amounts stated in the relevant entity's books, in accordance with accounting principles that are generally accepted for the type of business carried on by that person. (A specific accounting standard – e.g., GAAP, IFRS – is not mandated.) Affiliate “Affiliate” has the following meaning for the purposes of the Act: – One entity is affiliated with another entity if (i) one of them is a subsidiary of the other, (ii) both are subsidiaries of the same entity, or (iii) each of them is controlled by the same entity or individual. – If two entities are affiliated with the same entity at the same time, they are deemed to be affiliates of each other. – A n individual is affiliated with an entity if the individual controls the entity. – A n entity is a subsidiary of another entity if it is controlled by that other entity. – A corporation is controlled by an entity or an individual if securities of the corporation to which are attached more than 50% of the votes that may be cast to elect directors of the corporation are held, directly or indirectly, whether through one or more subsidiaries or otherwise, other than by way of security only, by or for the benefit of that entity or individual, and the votes attached to those securities are sufficient, if exercised, to elect a majority of the directors of the corporation.
– A n entity other than a corporation is controlled by an entity or individual if the entity or individual, directly or indirectly, whether through one or more subsidiaries or otherwise, holds an interest in the non-corporate entity that entitles the holder(s) to receive more than 50% of the profits of that entity or more than 50% of its assets on dissolution. Assets in Canada The Notifiable Transactions Regulations set out the procedure for calculating the aggregate value of assets and gross revenues from sales for purposes of the party- and transaction-size thresholds. The asset assessment for both the party- and transaction-size thresholds is based (in part) on assets located in Canada. Adjustments may be required depending on the particular circumstances. For example, parties may deduct – in certain circumstances, amounts that represent duplication arising from transactions between affiliates; – a ny amount that represents duplication arising from an ownership interest (including minority interests) of one person in another person; and – a ny amount provided for depreciation or diminution of value (as reflected in the financial statements for the most recently completed fiscal year). Subsequent transactions or events may also affect relevant asset values – for example: – w ritedowns or re-evaluations for financial reporting purposes of the value of any assets; – d ispositions, acquisitions or reorganizations that are likely to have a material effect on the aggregate value of assets; and – a greements or other events that are likely to have a material effect on the aggregate value of assets.
12
Davies | dwpv.com
Other Exemptions Some of the provisions setting out additional exemptions are highly technical, and parties should review their circumstances with competition law counsel. Other exemptions include the following:
Notification Form The form to be completed by each party to the transaction requires specific statutorily prescribed information about the transaction (e.g., structure and consideration); the business of each of the parties and their respective affiliates; detailed customer and supplier information; and all studies, surveys, analyses and reports that were prepared or received by an officer or director of the party for the purpose of evaluating or analyzing the proposed transaction with respect to market shares, competition, competitors, markets, potential for sales growth or expansion into new products or geographic regions.
(a) Acquisitions of Voting Shares or Interests in Combinations Solely for the Purpose of Underwriting the Shares or Interests
Underwriting of a security refers to the primary or secondary distribution of the security, in respect of which a prospectus is required to be filed, accepted or approved under a Canadian or foreign securities law regime, or would be required to be filed, accepted or approved but for an express exemption under a Canadian or foreign securities law regime. (b) Gifts, Intestate Successions or Testamentary Dispositions Gifts, intestate successions and testamentary dispositions are exempt from notification. (c) Transactions Exempted by the Canadian Minister of Finance A merger under the federal Bank Act, Cooperative Credit Associations Act, Insurance Companies Act or Trust and Loan Companies Act is exempt from merger notification and review if the Canadian Minister of Finance has certified to the Commissioner that the merger is in the public interest. (d) Asset Securitization Transactions The Notifiable Transactions Regulations exempt certain types of transactions involving transfers of financial assets that are entered into for the purpose of obtaining funds or credit or for related financial purposes whereby the financial assets continue to be administered either by the transferor or by an agent, trustee or other person who meets specified criteria.
13
Pre-Merger Notification Guide
Key Contacts If you would like to discuss any of the issues raised in this publication or would like to receive more information, please contact any of the individuals listed below or visit our website at www.dwpv.com.
Charles Tingley Partner 416.367.6963 ctingley@dwpv.com
John Bodrug Partner 416.863.5576 jbodrug@dwpv.com
Anita Banicevic Partner 416.863.5523 abanicevic@dwpv.com
Jim Dinning Partner 416.367.7462 jdinning@dwpv.com
Elisa K. Kearney Partner 416.367.7450 ekearney@dwpv.com
14
Davies | dwpv.com
About Davies
Davies is a leading Canadian business law firm focused on high-stakes matters. Tackling our clients’ issues with clarity and speed, we are consistently at the heart of their most complex deals and cases. With offices in Toronto, Montréal and New York, the firm’s capabilities extend across borders. Our lawyers are internationally recognized for their technical rigour and ability to create solutions for our clients that simply work. Considered a top-tier firm in each of our core practice areas, we represent a wide range of organizations across industries in North America and abroad. Contact any of our lawyers to discuss your situation or visit us at www.dwpv.com.
The information in this publication should not be relied upon as legal advice. We encourage you to contact us directly with any specific questions. © 2026 Davies Ward Phillips & Vineberg LLP. All rights reserved.
15
Pre-Merger Notification Guide
TORONTO
MONTRÉAL
NEW YORK
155 Wellington Street West Toronto ON Canada M5V 3J7 416.863.0900
1501 McGill College Avenue Montréal QC Canada H3A 3N9 514.841.6400
900 Third Avenue New York NY U.S.A. 10022 212.588.5500
DAVIES WARD PHILLIPS & VINEBERG llp
Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18Powered by FlippingBook