External Usability Testing Proposal

TITLE OF INFORMATION COLLECTION:
External Customer Usability Testing for Premerger E-Filing System

PURPOSE:
The FTC is currently modernizing the method by which it accepts Hart-Scott-Rodino (HSR)
filings from companies pursuing mergers and acquisitions as part of its Premerger Notification
Program. As part of this project, the FTC is developing an electronic filing system that allows
filers to submit their filings electronically via a web-based portal. At this point in the
development process, testing of the web-based filing portal and subsequent comment by likely
users will provide critical feedback for the development team regarding the usability of the portal
for a variety of filing contexts and scenarios. The FTC plans to ask existing customers (select
private law firm attorneys who frequently prepare and submit HSR filings for their clients with
the FTC) to access a test version of the web-based filing portal and complete a testing protocol
that will include preparing and submitting "dummy" filings, taking certain regular postsubmission actions related to the "dummy" filings, and testing collaboration features. After the
participating attorneys complete the testing protocol, the FTC would solicit general comments on
the usability of the filing portal, including details of any defects found during the testing process.
This effort will provide actionable feedback that will better ensure that the electronic filing
system will meet the needs of the agency's stakeholders and will contribute directly to the
improvement of the FTC's administration of the Premerger Notification Program.

DESCRIPTION OF RESPONDENTS:
Private law firm attorneys who frequently prepare and submit HSR filings with the FTC

TYPE OF COLLECTION: (Check one)
[ ] Customer Comment Card/Complaint Form
[ ] Customer Satisfaction Survey
[x] Usability Testing (e.g., Website or Software)
[ ] Small Discussion Group
[ ] Focus Groups
[ ] Other: ___________________

CERTIFICATION:
I certify the following to be true:
1. The collection is voluntary.
2. The collection is low-burden for respondents and low-cost for the Federal Government.
3. The collection is non-controversial and does not raise issues of concern to other federal
agencies.
4. The results are not intended to be disseminated to the public.
5. Information gathered will not be used for the purpose of substantially informing
influential policy decisions.

6. The collection is targeted to the solicitation of opinions from respondents who have
experience with the program or may have experience with the program in the future.
Name: Robert L. Jones, Assistant Director, Premerger Notification Office, Bureau of
Competition, Federal Trade Commission

Personally Identifiable Information:
1. Is personally identifiable information (PII) collected?
[ ] Yes
[x] No
2. If Yes, will any information that is collected be included in records that are subject to the
Privacy Act of 1974?
[ ] Yes
[ ] No
3. If Yes, has an up-to-date System of Records Notice (SORN) been published?
[ ] Yes
[ ] No

Gifts or Payments:
Is an incentive (e.g., money or reimbursement of expenses, token of appreciation) provided to
participants?
[ ] Yes
[x] No

BURDEN HOURS:
Category of respondent
Private sector (law firm attorneys
who frequently prepare and submit
HSR filings with the FTC)
Total

No. of Respondents
40

40

Participation Time
3 hours

Burden
120 hours

120 hours

FEDERAL COST:
The estimated annual cost to the Federal Government is minimal and outweighed by any
potential costs associated with not updating the current filing system.

If you are conducting a focus group, survey, or plan to employ statistical methods, please
provide answers to the following questions:
Not applicable
The selection of your targeted respondents:

Do you have a customer list or something similar that defines the universe of potential
respondents and do you have a sampling plan for selecting from this universe?
[ ] Yes
[ ] No
If the answer is yes, please provide a description of both below (or attach the sampling
plan)? If the answer is no, please provide a description of how you plan to identify your
potential group of respondents and how you will select them?
Administration of the Instrument:
1. How will you collect the information? (Check all that apply)
[ ] Web-based or other forms of Social Media
[ ] Telephone
[ ] In-person
[ ] Mail
[ ] Other, Explain: The focus groups will be conducted via Zoom video conferencing.
2. Will interviewers or facilitators be used?
[ ] Yes
[ ] No