Articles Posted in Junk Fees

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10 June 2024
See how JMBM’s Global Hospitality Group® can help you.
Click here for the latest articles on Junk Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers. We represent owners, developers, lenders, and management of hotels, restaurants, and other hospitality-related properties. We advise them on litigation, labor, regulatory compliance, contracts, transactions, financing, development, and strategies.

Mark S. Adams is the go-to senior lawyer in JMBM’s hospitality litigation team for assessing legal exposure, pursuing legitimate claims, and defending a client’s rights involving hospitality matters.

Jim Butler caught up with Mark to find out what all the fuss is about over California’s Junk Fee law (SB 478) and a proposed amendment by SB 1524 that has consumer advocates for transparent consumer prices in an uproar.

Jim Butler

 

 

 As a hospitality litigator and advisor, you have been at the forefront in junk fee matters for many years, and have written extensively about the latest developments.

Tell us what all the fuss is about concerning the California Junk Fee Law.
Mark S. Adams

 

 

 

 

 

 

 

 

 

 

 

 

 In October 2023, California passed a law (SB 478) that declared junk fees to be a prohibited, misleading business practice. Anyone who advertises a price for goods or services must provide the total cost on first contact. In other words, drip pricing is illegal. Sellers cannot use a come-on price to get attention with later disclosure of additional mandatory fees or charges.

See California bans Junk Fees as of July 1, 2024. Good bye to junk fees, resort fees, mandatory service charges, and drip pricing. Hello to – the fruits of SB 478.

California was the first state in the country to adopt such a comprehensive law, and it was widely hailed as a consumer victory. However, the substantive provisions of the California Junk Fee law are scheduled to become effective on July 1, 2024. And on June 6, 2024, William Dodd (with the support of the California Restaurant Association) introduced SB 1524 to exempt the restaurant industry from the California Junk Fee Law.

See Pricing transparency without hidden mandatory junk fees. Does this apply to restaurants too? New California proposed law (SB 1524 ) says “No!” Can this be right?
Jim Butler

 

 Isn’t this blatant preference of special interest legislation over consumer protection?
Mark S. Adams

 

 

 

 

 

 

 

 

 

 

 

 I have seen some strong criticism of the proposed SB 1524 as special interest legislation gutting landmark consumer protection. It certainly does make the playing field uneven. We have heard complaints from many other businesses affected by SB 478 who are not getting similar benefits. Just ask hotel owners or ticket sales companies.

Before Senator Dodd’s latest proposal, there were a couple of exemptions in SB 478 for certain highly regulated businesses who comply with their primary regulator’s detailed rules (such as broadband services complying with FTC regulations, or financial entities complying with relevant regulations such as the Financial Code, Truth in Lending or the Federal Reserve Act).

But SB 1524 is an outright exemption from SB 478 for any “items sold by a restaurant, bar, or other food service provider, or pursuant to a contract for banquet or catering services.”

The bill would permit drip pricing, as long as the additional mandatory fees are conspicuously set out in the advertisement, menu or other display.
Jim Butler Doesn’t that provision gut SB 478?
Mark S. Adams

 

 

 

 

 

 

 

 

 

 

 

 

 Yes and no. It does exempt the restaurant industry from SB 478’s ban on junk fees, as long as the service charge or administrative fee or health compliance charge is disclosed. The consumer is not entitled to get the total cost on first exposure to price, as she would be if looking at a promotion for a hotel stay. Some people feel this is a violation of the honest pricing or transparent pricing mandate behind the reform legislation.

But unless further amended, as of July 1, 2024, SB 478 will affect every other business dealing with California consumers. Of course, most of these other affected businesses feels this is unfair. Most of them disclose various mandatory fees somewhere in the sale process. It is just that they disclose them after the initial advertised price, and after the consumer has invested time in researching the goods or services, or filling in required information to get to a form. Hiding the additional fees just frustrates open competition and makes it difficult for consumers to make wise decisions.

SB 478 is only gutted as to the restaurant industry. It applies to everyone else. Is that fair? Does that serve the public?

I guess we will have to see what the California legislature decides.

California DOJ SB 478 FAQs

Anticipating the effectiveness of the law, on May 8, 2024, the California Department of Justice released a set of SB 478 Frequently Asked Questions (SB 478 FAQs) to provide guidance on the law.

Although these SB 478 FAQs may become moot as to restaurants, they will continue to apply to all other businesses, unless exempted.

 

CONTINUE READING →

Published on:

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6 June 2024
See how JMBM’s Global Hospitality Group® can help you.
Click here for the latest articles on Junk Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers. We represent owners, developers, lenders, and management of hotels, restaurants, and other hospitality-related properties. We advise them on litigation, labor, regulatory compliance, contracts, transactions, financing, development, and strategies.

Pricing transparency without hidden mandatory junk fees. Does this apply to restaurants too? New California proposed law (SB 1524 ) says “No!” Can this be right?

by

Mark S. Adams
Hotel Dispute Lawyer, Partner & Senior Member
JMBM’s Global Hospitality Group

For more than 20 years consumers have complained about hidden mandatory fees, junk fees, resort fees, destination fees, service fees, administration fees, health fees, surcharges, connection fees, and similar charges, whatever they are called.

California’s new “Honest Pricing Law,” SB 478, cracks down on hidden fees, requiring businesses to advertise and list a price that includes all mandatory charges. This applies to most goods and services, but a new bill, SB 1524, proposes an exception for restaurants.

SB 478: Transparent Pricing and the End of Junk Fees

SB 478, taking effect July 1, 2024, prohibits businesses from advertising a misleadingly low price and then tacking on hidden mandatory fees at checkout. This includes service charges, resort fees, and other surprise surcharges. Consumers have long complained about these “junk fees,” and SB 478 aims to create price transparency. California’s Civil Code Section 1770(a)(29), amended by SB 478, prohibits unfair business practices like misrepresenting product qualities. Importantly, it requires businesses to advertise prices that include all mandatory fees, excluding only government taxes and reasonable shipping costs. This transparency aims to protect consumers from unexpected charges. Certain industries, like those complying with FCC regulations for internet access or those already subject to federal and state disclosure laws for financial services, are exempt from this specific provision.

SB 1524: A Special Exception for Restaurants?

Introduced on June 6, 2024, SB 1524 would allow restaurants to continue adding mandatory service charges, gratuities, and other fees on top of their advertised prices, as long as these fees are clearly disclosed on menus or advertisements. The proposed amendment to Civil Code 1770, would add a new subsection 29(D) to exempt restaurants from the transparent pricing mandate of in that section by adding this language:

(D)  For purposes of this paragraph, “advertising, displaying,  or offering a price for a good or service” does not include advertising or displaying the price of individual food or beverage items sold by a restaurant, bar, or other food service provider, or sold pursuant to a contract for banquet or catering services, provided that any service charge, mandatory gratuity, or other mandatory fee or charge is clearly and conspicuously displayed on the advertisement, menu, or other display.

The Debate: Transparency vs. Industry Flexibility

This exemption has raised concerns about consumer protection and a level playing field for businesses. SB 1524’s proponents, including the restaurant industry and the labor union UNITE HERE, argue that it allows restaurants flexibility in covering costs like employee benefits. Opponents argue that this exemption undermines the core purpose of SB 478 – price transparency for consumers. They question why restaurants should be treated differently from other businesses and point out the Federal Trade Commission’s stance that hidden fees are deceptive practices. CONTINUE READING →

Published on:

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17 May 2024
Click here for the latest articles on Resort Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers. We represent owners, developers, lenders, and management of hotels, restaurants, and other hospitality-related properties. We advise them on litigation, labor, regulatory compliance, contracts, transactions, financing, development, and strategies.

Consumers hate drip pricing and junk fees

Consumers and politicians have complained about drip pricing and junk fees for more than 20 years. There’s a close connection between the two, but they are not exactly the same thing.

  • Junk fees: These are generally any unexpected, often mandatory fees added to the advertised price of a good or service. They can be hidden or poorly explained, making it difficult for consumers to anticipate the true cost. Examples include service fees on concert tickets, credit card processing fees, or resort fees at hotels.
  • Drip pricing: This is a specific tactic used to introduce junk fees. It involves advertising a lower headline price initially and then revealing additional mandatory fees later in the purchasing process, often in small print or during checkout. This creates a misleading impression of the actual cost and makes it harder for consumers to compare prices accurately.

So, all drip pricing involves junk fees, but not all junk fees involve drip pricing. For instance, a credit card with an “electronic service fee” added – even if clearly advertised — would not be considered drip pricing, even though it is a type of a junk fee.

Here’s an analogy: Drip pricing is like revealing all the ingredients in a recipe one by one, after having already taken a bite. Junk fees are like the unexpected or ill-defined ingredients that might not have been listed at all.

The first reports of  hotels charging resort fees (or similar charges) can be traced back to the year 2000. We are not sure if hotels invented the practice or were just amongst the early innovators. But in any event, the various mandatory fees with various labels soon became widespread throughout the hospitality industry and other industries including hotels, restaurants, food delivery services, live-event ticket sales, transportation such as car rentals and airlines, and many others.

FTC concern about drip pricing, junk fees, and deceptive practices

On November 9, 2023, the Federal Trade Commission (FTC) issued notice of a proposed rule on “Unfair or Deceptive Fees.” This development is discussed in the Blog below by my partner, Mark S. Adams.

FTC Cracks Down on Hidden Fees:
Upfront Pricing Is Coming

by

Mark S. Adams
Hotel Dispute Lawyer, Partner & Senior Member
JMBM’s Global Hospitality Group

Federal Trade Commission (FTC) is proposing a new weapon in the fight against hidden fees, surprise charges that inflate the cost of everything from hotel rooms and restaurant charges to concert tickets and college tuition. This proposed rule addresses prevalent fee practices that are unlawful under Section 5 of the FTC Act, 15 U.S.C. 45, and declares them to be unfair or deceptive to consumers. This “junk fee” crackdown would impact a wide range of industries, aiming to bring transparency to how businesses disclose their true costs.  Generally, the proposed rule makes two changes: Upfront Pricing and Deceptive Fees. CONTINUE READING →

Published on:

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10 May 2024
Click here for the latest articles on Resort Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers. We represent owners, developers, lenders, and management of hotels, restaurants, and other hospitality-related properties. We advise them on litigation, labor, regulatory compliance, contracts, transactions, financing, development, and strategies.

Consumers and politicians have complained about junk fees for more than 20 years. The first reports of hotels charging resort fees (or similar charges) can be traced back to the year 2000. We are not sure if hotels invented the practice or were just amongst the early innovators. But in any event, the various mandatory fees with various labels soon became widespread throughout the hospitality industry and other industries, including hotels, restaurants, food delivery services, live-event ticket sales, transportation such as car rentals and airlines, and many others.

In the hotel industry, these hidden fees have different names, such as resort fees, destination fees, or surcharges. Other industries have used labels such as service fees, delivery fees, installation fees, and administrative fees, just to name a few. But they are all “junk fees”—mandatory hidden fees that are not fully disclosed at initial customer contact but only revealed later in the sales process.

As of July 1, 2024, California will implement a high-profile law to ban such junk fees unless they are specifically exempted. Here are the details.

Junk Fees are banned in California as of July 1, 2024!
What does the California Junk Fee Law (SB 478) mean?

by

Mark S. Adams
Hotel Dispute Lawyer, Partner & Senior Member
JMBM’s Global Hospitality Group

California businesses brace for Senate Bill 478‘s impact. SB 478 was signed by Governor Newsom in October 2023 and became effective July 1, 2024. It cracks down on hidden fees, often referred to as “junk fees” and “drip pricing” (because the full cost is only disclosed drip by drip). It will likely change how businesses approach pricing strategies. Many say it is part of a nationwide response to President Joe Biden’s call to eliminate Junk Fees.

What’s in a name? SB 478 or California Junk Fee Law?

The confusion starts with how to reference the new law. Many refer to it by the Senate Bill number assigned when it was first introduced in the California Senate, and the SB 478 moniker continues to be popular with many, even after signed into law.

We also like to call it the California Junk Fee Law because SB 478 does not describe the focus of the legislation. It is really a collection of amendments to the various sections of the California Civil Code, Government Code, and Vehicle Code, as described in more detail below.

Many consumer groups and plaintiffs’ lawyers seem to refer to it as amendments to the California Consumers Legal Remedies Act, or the CRLA. Their focus is on enforcing the law and the remedies given to the government and consumers to bring private legal actions.

Still, others refer to it by the underlying prohibited practices, calling it the California law on drip pricing, hidden fees, bait-and-switch, unfair competition, unfair business practices, consumer fraud, and the like. These advocates generally include California plaintiffs’ lawyers and state and local prosecutors who largely rely on the California Unfair Competition Law (UCL) and the Consumers Legal Remedies Act (CELA) The new California Junk Fee Law is expected to facilitate new claims against businesses under these laws.

We may use all these terms interchangeably, but we tend to prefer the California Junk Fee Law. CONTINUE READING →

Published on:

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22 December 2023

See how JMBM’s Global Hospitality Group® can help you.
Click here for the latest articles on Resort Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers. We represent owners, developers, lenders, and management of hotels, restaurants, and other hospitality-related properties. We advise them on litigation, labor, regulatory compliance, contracts, transactions, financing, development, and strategies.

Hotel Dispute Lawyer: How Pennsylvania Resort Fees Settlements Could Play Out for US Hotel Industry

Hospitality Litigation, Arbitration & Dispute Resolution

On December 12, 2023, Mark S. Adams, Hotel Dispute Lawyer, was a guest on the Hotel News Now podcast where he discussed the effects of mandatory fee disclosure litigation in Pennsylvania on the hotel industry.

Consumer advocacy groups, law firms and federal and state governments have begun to push back on hidden resort fees, which are often not disclosed until customers near the end of the booking process. Resort fees are charged in addition to hotel room rates and can include things like amenity fees and destination charges.

In Pennsylvania, the state’s attorney general reached settlement agreements with Omni Hotels & Resorts, Choice Hotels International and Marriott International over their fee disclosure practices. According to Adams, the main objective in these cases was to ensure full transparency. If a hotel has a mandatory fee, they will have to let customers know upfront.

“I see the impact as being multifaceted,” explained Adams. “One, it’s good for the consumers because you know what you’re buying. Two, I think it’s actually good for the industry.”

He went on to explain that because some of the biggest hotel brands have become compliant with full disclosure, the smaller brands will get on board. CONTINUE READING →

Published on:

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19 December 2023

See how JMBM’s Global Hospitality Group® can help you.
Click here for the latest articles on Resort Fee Litigation.

On July 1, 2024, a comprehensive ban on pricing goods and services without including all mandatory fees will go into effect in California. This ban is the result of a bill recently signed into law by Governor Gavin Newsom, and similar proposed legislation has gained bi-partisan support from state governments and federal authorities. In the below article, JMBM partner Mark Adams discusses the implications of these legal developments for hotel owners. He emphasizes the need for full transparency to avoid financial penalties, litigation, and reputational damage.

The Final Check-Out: Bidding Farewell to Undisclosed Mandatory Resort Fees

by

Mark S. Adams, Hotel Dispute Lawyer
Partner & Senior Member
JMBM’s Global Hospitality Group®

Reprinted from the Hotel Business Review with permission from www.HotelExecutive.com.

In October this year, California Governor Gavin Newsom signed into law (effective July 1, 2024) a sweeping ban on pricing goods and services without including all mandatory fees or charges.

Presently pending in the U.S. Senate is a bipartisan-supported bill that would do the same.

These bills join state governments, federal authorities, state attorneys general, and consumer advocacy groups in intensified scrutiny of undisclosed mandatory resort fees included in hotel rates. Additionally, several state attorney generals and consumer groups are targeting hotels that charge undisclosed resort fees.

In response to this developing trend, it is imperative for hotel owners to quickly implement full transparency, revealing the total cost of mandatory resort fees upfront. Failure to do so may result in significant financial penalties, expensive litigation, and reputational damage among consumers, who often do not view these fees favorably.

What are Resort Fees?

Resort fees are extra charges imposed by hotels and resorts, ostensibly for providing certain amenities. This additional cost is typically calculated daily and added to the basic room rate. Resort fees are sometimes relabeled as a facility fee, destination fee, amenity fee, urban fee, or  resort charge. In the end, they are all the same thing; and even if a guest does not actually use the amenities associated with the resort fees, they are still required to pay for them.

Consumer Complaints About Hotel Resort Fees

Resort fees have become a significant point of contention for consumers worldwide. These mandatory charges, often added to hotel bills after booking, have been criticized for their lack of transparency and fairness. Many consumers claim to be blindsided by these additional charges, only realizing they are being charged a resort fee when they check out. This lack of upfront disclosure makes it difficult for consumers to accurately compare room costs and budget for their stay. CONTINUE READING →

Published on:

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26 September 2019

Click here for the latest articles on Resort Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers. We represent owners, developers, lenders, and management of hotels, restaurants, and other hospitality-related properties. We advise them on litigation, labor, regulatory compliance, contracts, transactions, financing, development, and strategies.

We have provided counsel on Attorney General investigations. We understand the best defenses to consumer and government agency claims that Resort Fee practices constitute violations of state consumer protection actions, the Federal Trade Commission Act and other causes of action based on misrepresentation, consumer fraud, and unfair business practices.

On September 25, 2019, a bill was introduced in the House of Representatives that would expressly make hotel resort fees and other mandatory charges illegal.

H.R. 4489 is entitled the Hotel Advertising Transparency Act of 2019. It was introduced as bipartisan legislation by Representative Eddie Bernice Johnson (D-TX) and Representative Jeff Fortenberry (R-NE).

H.R. 4489 declares that the practice of charging mandatory fees which are not disclosed with the advertised rate of a hotel room (excluding taxes and fees imposed by a government) is unfair and deceptive to consumers. It expressly authorizes the Federal Trade Commission (FTC) to enforce the legislation and also permits State Attorneys General to do so as well, coordinating with the FTC.

Click here to see the complete text of H.R. 4489, the Hotel Advertising Transparency Act of 2019.

How angry are consumers? Will hotels lose guests over resort fees? Will H.R. 4489 become law? What will be the outcome of the litigation filed against Hilton and Marriott?

We don’t know the answers. But these questions are being asked not only by attorneys general and legislators, they are on the lips of movers and shakers throughout the industry.

How to get help with Resort Fee litigation issues CONTINUE READING →

Published on:

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24 July 2019

Click here for the latest articles on Resort Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers. We represent owners, developers, lenders, and management of hotels, restaurants, and other hospitality-related properties. We advise them on litigation, labor, regulatory compliance, contracts, transactions, financing, development, and strategies.

Another state Attorney General joins in the Resort Fee litigation – this time suing Hilton

On July 23, 2019, Attorney General Doug Patterson filed a lawsuit against Hilton, alleging that it has engaged in deceptive and misleading pricing practices and failure to disclose fees in violation of Nebraska’s consumer protection laws. The complaint seeks injunctive relief to force Hilton to advertise the true prices of its hotel rooms, provide damages for Nebraska consumers, statutory civil penalties of $2,000 for each violation, and costs for investigation and legal action. Click here to see the Nebraska complaint against Hilton.

This new lawsuit is particularly significant because it was filed just two weeks after the District of Columbia filed a similar suit against Marriott.

A new template for other Attorneys General and plaintiff’s class action lawyers?

Many industry observers believe that the two recent lawsuits against Marriott and Hilton provide a virtual “template” for other AGs and class action lawyers to mark up and file – potentially against all hotel franchise companies, hotel operators, and hotel owners involved with any hotel that has used Resort Fees or other mandatory fees or charges imposed on all hotel guests which are not included in the initially quoted room rate.

The conduct complained of in the DC and Nebraska lawsuits traces the pattern outlined by the January 2017 FTC Report as deceptive and misleading under the FTC Act and most state consumer protection laws (that are based on the FTC Act). Although these first two suits are against big hotel companies, they are just at the top of the pyramid and provide high-profile examples of targets for plaintiffs. Similar actions would likely exist against every other brand, operator or owner of a hotel using undisclosed Resort Fees in their advertised room rates. CONTINUE READING →

Published on:

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09 July 2019

Click here for the latest articles on Resort Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers. We represent owners, developers, lenders, and management of hotels, restaurants, and other hospitality-related properties. We advise them on litigation, labor, regulatory compliance, contracts, transactions, financing, development, and strategies.

Hotel Lawyer: We hate to say “we told you so” on Resort Fee litigation

We have been watching the Resort Fee issue for several years. We have advised clients on litigation, compliance and risk mitigation strategies. We have provided counsel on Attorney General investigations. We understand the best defenses to consumer and government agency claims that Resort Fee practices constitute violations of state consumer protection actions, the Federal Trade Commission Act and other cause of action based on misrepresentation, consumer fraud, and unfair business practices.

We have cautioned that consumer frustration over this issue is very high, and government agencies have periodically shown significant interest in jumping on a populist bandwagon. But today, it looks like the situation may have finally reached a turning point.

Hotel Resort Fees litigation back in the news

On July 9, 2019, the Attorney General for the District of Columbia sued Marriott International in Superior Court for the District of Columbia over its policies and practices regarding “Resort Fees” and “drip pricing.” The lawsuit says that Marriott’s use of Resort Fee pricing misrepresents material facts (and tends to mislead consumers), and is an unlawful trade practice that violates the District’s Consumer Protection Act.

Resort Fees is a shorthand expression for all mandatory fees and charges imposed by a hotel on its guests which are not included in the quoted room rate. They may have a variety of names such as resort fees, service fees, amenity fees, destination fees, surcharges or otherwise. But the common feature is that they are non-optional charges to the guest which are not included in the initially quoted room rate.

Copy of the complaint in DC vs. Marriott

Click here to view a copy of the complaint.

Potential importance of this Resort Fee case

Resort Fees have been around since at least 1997, but by 2017 they were estimated to have grown to more than $2.7 billion. They seem to be gaining greater popularity with hoteliers and continue to be a top annoyance for hotel guest. The practices the new lawsuit complains of are widely used throughout the industry by a large number of hotel brands and operators.

While some hotel companies may seek to distinguish their practices from those of Marriott in this case, we believe that most Resort Fee cases will present similar liabilities, challenges and compliance problems that Marriott will face.

CONTINUE READING →

Published on:

By

12 October 2017
Click here for the latest articles on Resort Fee Litigation.

Note: If you are a consumer with a Junk Fee issue, please do NOT contact us! We do not represent consumers. We represent owners, developers, lenders, and management of hotels, restaurants, and other hospitality-related properties. We advise them on litigation, labor, regulatory compliance, contracts, transactions, financing, development, and strategies.

What does the FTC say is your potential liability for mandatory hotel charges?

In evaluating what you should do about the new furor over mandatory hotel charges, it would be helpful to have a clearer understanding of what the FTC seems to be saying on the issue. The chart below is our translation into “street English” of the FTC pronouncements discussed earlier. (See How Resort Fees became an explosive $2.7 billion issue which contains links to the original FTC press release of November 29, 2012 and the most recent FTC Economic Analysis of Hotel Resort Fees of January 2017.)

We believe we understand what the FTC is saying. We may not agree with it. We do not know whether the Trump administration will rein in the FTC on its perceived mission regarding resort fees, and we do not know whether the current FTC position will be upheld as a valid interpretation of the law. However, courts normally accord great deference to the interpretation of agencies charged with administering their laws, and it is imprudent to ignore the FTC’s recent actions.

In weighing options, even if they ultimately win on legal issues, hoteliers should also consider the negative effects of litigation — including direct costs in terms of legal fees, senior management time, and good will. And there are a number of worrisome plaintiffs who may pursue the issue, including the FTC, State Attorneys General, other governmental and consumer groups, and class action plaintiffs’ lawyers. Any victories by the hotel industry may be largely offset by the costs to obtain them.

So what are your options on mandatory Resort Fees?

The basic thrust of the actions by the FTC, the investigation by the State Attorneys General and most consumer class action suits is that it is a deceptive and misleading business practice for hotels to advertise their room rate online unless the first and most prominent price given includes all mandatory Resort Fees and other charges. They say that it is not sufficient to give the room rate and then have a less prominent disclosure of additional charges. CONTINUE READING →

Contact Information
Jim Butler, Chairman
Global Hospitality Group®
Jeffer Mangels Butler & Mitchell LLP
(310) 201-3526 • jbutler@jmbm.com
www.HotelLawyer.com

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