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Case No. CU-2013-303724-1
trivago GmbH
c/o [ ]
555 17th Street, Suite 3200
Denver, CO 80202
Attn: [ ], Esq.
Dear Mr. [ ]:
This is in response to your letter dated July 3, 2013 (the “Application”) to the Office of Foreign Assets Control (“OFAC”), on behalf of trivago GmbH (“trivago”), a German company majority-owned by Expedia, Inc., requesting interpretive guidance on the applicability of the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the “CACR”), to trivago’s internet search and referral services related to lodging in Cuba.
In your Application, you explain that trivago is a website that aggregates data on hotel lodging, including hotels in Cuba. The website also provides information about the hotel, such as pictures and peer reviews, but the website does not host hotel bookings or contain any...
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1) BACKGROUND
The applicant, as an entity majority-owned by a U.S. person (Expedia, Inc.), is a “person subject to the jurisdiction of the United States” for purposes of section 515.329 of the CACR, making it subject to the prohibitions of the CACR as if it were an ordinary U.S. person.
As described in the guidance letter, the applicant operates a:
“website that aggregates data on hotel lodging, including hotels in Cuba. The website also provides information about the hotel, such as pictures and peer reviews, but the website does not host hotel bookings or contain any other operational component. If a user wants to make a reservation, the user clicks on a link that takes the user directly to the hotel’s website or to an Online Travel Agency (‘OTA’) for booking and additional information....