You may list only the authors and recipients of the emails with the 4c content.
Question
From: Whitehead, Nora <nwhitehead@ftc.gov>
Sent: Tuesday, October 12, 2021 11:07:03 AM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: HSRHelp <HSRHelp@ftc.gov>
Subject: RE: Item 4(c) - Authors and Recipients of Emails
You may list only the authors and recipients of the emails with the 4c content.
From: [Redacted]
Sent: Tuesday, October 12, 2021 2:21:46 AM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp <HSRHelp@ftc.gov>
Cc: [Redacted]
Subject: Item 4(c) - Authors and Recipients
Hello PNO Staff,
We have a question regarding how to describe an email thread in the documentary attachment list. The Item 4(c) tipsheet at https://www.ftc.gov/system/files/attachments/hsr-resources/4ctipsheet.pdf indicates:
The description of the email chain in a 4(c) log would list the range of dates beginning with the date of the reply email and end with the original email down the chain. The names and titles of all authors and recipients should also be listed in the 4(c) log. If the reply contained 4(c) content but the original down the chain did not, you would include the entire chain as a 4(c) document and describe it in the 4(c) log as discussed above. If the original email contained 4(c) content, but no replies to or forwarding of the original email contained 4(c) content, then only the original email would be responsive to Item 4(c).
Where the 10th email in an email chain is contains responsive 4(c) content, but none of the prior 9 contain responsive content, is it sufficient to list just the author and recipients of the last responsive email, the 10th in the chain? Or if not, is it sufficient to list all authors, identifying them as the authors, and all recipients and identifying them as recipients, of the entire email chain without separating them out by date?
Where 2 of the 10 emails in the thread contain responsive 4(c) content, do we need to provide just the authors and recipient(s) of the two responsive emails in the chain or an entire list of the authors and recipients for each of the 10 emails comprising the email chain?