Sabre Corporation, 2019 10-K Filing, 2023 Q1 10-Q Filing

Date issued: Feb. 15 2019

Last substantive commentary amendment:
Jun. 27 2023

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TURBOFAC Commentary (1083 words)

Notes:

1) Sabre is a provider of a "global distribution system" for travel (see full 10-K filing for operational details and footnote for certain excerpts) [1].

2) FACILITATION OF "NOT PROHIBITED" CUBA TRAVEL AND THE INFORMATIONAL MATERIALS EXEMPTION

With regard to Cuba, compare the guidance of 020416-FACRL-CU-01-Computer Reservation Systems, with the statement that Sabre can, on the basis of the informational materials exemption alone (515.206), "display on the Sabre GDS flight information for, and support booking and ticketing of, services of non-Cuban airlines that offer service to Cuba."

The GL at 515.572 allows U.S. persons to "to provide travel services in connection with travel-related transactions involving Cuba authorized pursuant to [the CACR]. That ostensibly applies only to travel that is, in principle, within the scope of the CACR as a threshold matter,...