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A Beatles reunion tour No-Action Letter — and 62,000 other newly added letters

July 28, 2013

Recently, we added to our collection of No-Action Letters correspondence from the SEC to an investor who was trying to fund his “dream” of a reunion tour of the Beatles a decade after the band broke up.  The letter was released by the SEC in October 1980, about six weeks before the assassination of John Lennon made such a reunion forever impossible.   (A link to the letter is below.)

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The Beatles reunion tour No-Action Letter was one of about 62,000 new (to us) No-Action Letters we added to our collection — expanding it by more than tenfold (yes, as in 10x).  We now have nearly 70,000 No-Action Letters going back over 40 years.

Previously, our collection was “complete,” but with an asterisk: we had all the No-Action Letters made electronically available by the SEC — some 5,800 going back to 1997.  That qualified claim of completeness is what most of our competitors (we won’t name any names) continue to be saddled with.   What it means in practical terms is that if you rely on one of those providers for access to No-Action Letters, you’re getting only a tiny fraction of what providers like Knowledge Mosaic (and, yes, Westlaw Business) make available and fully text-searchable.  Over 60,000 No-Action Letters exist but are out of your reach.  Such a diminished collection is kind of like a Beatles reunion tour without John Lennon.   And without Paul or George either.

The additional content is directly attributable to Knowledge Mosaic’s acquisition by LexisNexis earlier this year.  We were able to migrate Lexis’ vast collection of No-Action Letters to the Knowledge Mosaic platform, where the content can be searched either exclusively or alongside other SEC guidance data.   Did we mentioned that advanced, Boolean text search is now also available?   Or that we continue to harvest new documents within minutes of their being made available by the SEC?  The speed factor is especially important if you have custom alerts set up on No-Action Letters.

The expansion of SEC No-Action Letters is the best example yet of how the acquisition puts us in a position to offer a better Knowledge Mosaic than has ever been possible before.

What does the new expanded content mean for you, exactly?  Well, for starters, it means that you can find:

  • 34,158 letters from the Division of Corporation Finance.
  • 14,468 letters on Exchange Act Rule 14a-8.
  • 2,337 letters in which the SEC is “unable to concur” with the filer’s interpretation of a rule. (Since that means the SEC would indeed take “action” were the interpretation acted upon, perhaps these would more properly be called “Action Letters” rather than “No-Action Letters.”)
  • 15 letters in response to a request from Microsoft Corp.
  • 10 letters that offer guidance around whether a company’s repurchase plan constitutes an issuer tender offer.
  • 1 letter that concerns the offering of limited partnership units to fund a proposed Beatles reunion tour.

Our collection of SEC No-Action Letters is accessible though our Laws, Rules & Agency Materials page.  Use the Quickfind box at the upper right hand corner of that search page; or click the blue hyperlinked text for “SEC” under the Agency Materials list.  (Or just use this quick link).

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