FAC No. CU-151435

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TURBOFAC Commentary (128 words)

Notes:

1) Refer to comments to Havana Club Holding S.A. v. Galleon S.A., 203 F.3d 116 (2d Cir. 2000). This is the original version of the guidance letter excerpted in that opinion (in which the 2nd Circuit declines to reject OFAC's reasoning).

2) Contrast Kalantari v. NITV, Inc., 352 F.3d 1202 (9th Cir. 2003), and comments thereto, where assignment of a copyright was considered a transaction authorized as "ordinarily incident to" the generally licensed registration of a copyright, within the meaning of the boilerplate interpretive provision authorizing transactions "ordinarily incident" to licensed transactions. The now includes a boilerplate interpretive provision authorizing transactions "ordinarily incident" to licensed transactions (515.421), but it was only inserted in the CACR in 2015, prior to this litigation.

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FAC No. CU-151435

TURBOFAC Commentary (128 words)