December 19, 2017
VIA EDGAR
Ms. Cecilia Blye
Chief, Office of Global Security Risk
Securities and Exchange Commission
100 F Street, N. E.
Washington, D. C. 20549
U.S.A.
Re:trivago N.V.
Form 20-F for the Fiscal Year Ended December 31, 2016
Filed March 9, 2017
File No. 1-37959
Dear Ms. Blye:
On behalf of trivago N.V. ("trivago" or the "Company"), set forth below are the Company’s responses to the comments contained in your letter dated December 8, 2017, regarding the above-referenced filing. For your convenience, your comments are set forth in italics before each response.
Background
trivago is a global hotel search platform. We are focused on reshaping the way travelers search for and compare hotels, while enabling hotel advertisers to grow their businesses by providing access to a broad audience of travelers via our websites and apps. Our platform allows travelers to make informed...
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at least 9/2021, is majority-owned by Expedia Group, meaning that it was not a U.S. Person for the purposes of the repealed Sudan sanctions, but is currently subject to the ITSR by way of 560.215 and CACR by way of 515.319(d) (owned by a U.S. person).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...