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Interpretative Process & Staff Interpretative Letters


NASDAQ will provide a definitive interpretation of the application of NASDAQ Listing Rules to issuers. To receive such an interpretation, the issuer or its counsel must submit a written request, identifying the NASDAQ-listed company and providing the relevant facts. The letter should be sent to the company's Listing Qualifications analyst at the following address:

The NASDAQ Stock Market LLC
Listing Qualifications
9600 Blackwell Road
Rockville, MD 20850

Fax: +1 301 978 4028

Email: StaffInterpretations@nasdaqomx.com

Pursuant to Listing Rule 5602, a company is required to submit to NASDAQ a non-refundable fee in connection with a request for a written interpretation of the listing rules. NASDAQ offers two levels of service - regular timing and expedited. The fee for the regular timing is $5,000, and for the expedited, $15,000. The response times, as measured from the date that NASDAQ receives all information necessary to respond, are typically: (1) for the regular timing, within four weeks, and (2) for the expedited, less than four weeks, but at least one week. While it typically takes several weeks to issue an interpretative letter, NASDAQ will make every effort to accommodate a company's timing needs. Nonetheless, depending on the complexity of the issues, and the amount of time the company takes to respond to questions, NASDAQ may not be able to respond in the requested time frame. However, if we determine that an interpretative response was excessively delayed, we may, at our discretion, refund the fee.

A company may withdraw its request at any time prior to the issuance of the written interpretation by submitting a written request for the withdrawal to NASDAQ. For the purpose of satisfying this requirement, an email constitutes a written request. There will be no refund of the fees based on the withdrawal of the request for a written interpretation. If no written request to withdraw an interpretation is received, the interpretation will be issued.

NASDAQ does not impose fees for requests related to initial listing on The NASDAQ Stock Market or requests for a financial viability exception pursuant to Listing Rule 5635(f). Companies, that have a class of securities which have been suspended or delisted from NASDAQ, but the suspension or delisting decision is under review pursuant to the Rule 5800 Series, are eligible to request a written interpretation, subject to the payment of the appropriate fee.

For specific instructions on the submission of an interpretative request, please see Payment Form: Interpretative Request Fee .

Please contact Listing Qualifications at +1 877 536 2737 or +1 301 978 8008 with any questions regarding this process or with general questions regarding NASDAQ Listing Rules.

To provide transparency regarding our rules and policies, NASDAQ publishes anonymous summaries of these interpretative letters. These summaries are provided in the document below. All interpretative letters are based on the facts and circumstances arising in the particular matter and are based on NASDAQ's rules and policies in effect at the time of issuance.