Case No. CU-2013-303724-1

Date issued: Dec. 05 2013

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TURBOFAC Commentary (699 words)

Notes:

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....