LinkedIn Corporation, Correspondence with SEC Division of Corporation Finance (2013), re: 2012 10-K Filing; 2015 10-K Filing

Date issued: Apr. 23 2013

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TURBOFAC Commentary (1466 words)

Notes

This correspondence between LinkedIn and the SEC represents a notable set of interpretations of sanctions provisions, notable for their relative novelty and the likelihood that OFAC tacitly approves of the interpretations. For further commentary on the question of whether certain social media and other communications-related internet services are exempt from regulation, refer to sections 2 and 3 of General Note on Prohibitions, Licenses and Exemptions as Applied to Social Media and Other Communications-Related Internet Services and Software (System Ed. Note).

1) LINKEDIN SERVICES AND THE INTERNET SERVICES GENERAL LICENSES

First, note that Syria General License 5 is now 542.511 of the SySR. 515.578 (CACR), 560.540 (ITSR) and Ukraine/Crimea GL No. 9 are all as broad or broader than 542.511 of the SySR,...