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Securities Act of 1933
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Re: |
Vail Resorts, Inc. |
Based on the facts presented, the Division is unable to provide the requested relief regarding Vail's proposal to offer and sell condominium units without registration under the Securities Act. We will not provide retroactive relief and note that Vail began selling such condominium units prior to receiving a no-action position. Please note that we have not otherwise considered or reached a position on the issues raised in your letter.
This position is based on the representations made to the Division in your letter. Different facts or conditions might require a different result. This response expresses the Division's position on enforcement action only and does not express any legal conclusions on the questions presented.
Sincerely,
Kim McManus
Special Counsel
The Incoming Letter is in Acrobat format.
http://www.sec.gov/divisions/corpfin/cf-noaction/2007/vailresorts042507-2a1.htm
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