Trivago N.V., 2016 10-K Filing

Date issued: Dec. 19 2017

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TURBOFAC Commentary (1019 words)

Notes:


1) Trivago is a Dutch company that, as of 2013 and up through at least 9/2021, is majority-owned by Expedia Group, meaning that it was not a U.S. Person for the purposes of the repealed Sudan sanctions, but is currently subject to the ITSR by way of 560.215 and CACR by way of 515.319(d) (owned by a U.S. person). 


Trivago describes having received a "a written interpretive ruling" from OFAC stating that its business model is such that, even if it were a U.S. person, its activities would be generally exempt from regulation, at least in connection with activities concerning countries embargoed pursuant to IEEPA


trivago generates revenues primarily on a "cost-per-click," or "CPC," basis, whereby trivago charges an advertiser when a user clicks...