Case No. CU-2016-337943-1

Date issued: May. 22 2018

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (426 words)

Notes:

1) Compare Case No. CU-2016-332180-1 and Case No. CU-2016-334368-1, which are other guidance letters citing the GL (515.534) authorizing the negotiation of, and entry into, contingent contracts, and travel to Cuba for the purposes of the same.

2) RECEIPT/CREATION OF INFORMATIONAL MATERIALS FOR PRESUMABLY FOR FURTHER COMMERCIAL EXPLOITATION

The applicant entity here, STR, Inc., is essentially the hotel equivalent of the Airline Tariff Publishing Company that is the subject of Case No. MUL-372-1. Both are data-focused industry clearinghouses for information related to the hotel and airline industries; both solicit data from hotels/airlines worldwide and make such data available to their subscribers for a fee.

Here, STR seeks to "obtain hotel information from the Cuban government," i.e. a "list of hotels in Cuba from the Ministry of Tourism...