Berlin v. Renaissance Rental Partners, LLC

JOSÉ A. CABRANES, Circuit Judge:

The Interstate Land Sales Full Disclosure Act (“ISLA”), 15 U.S.C. § 1701 et seq., “protects individual buyers or lessees who purchase or lease lots in large, uncompleted housing developments, including condominiums, by mandating that developers make certain disclosures.” Bacolitsas v. 86th & 3rd Owner, LLC, 702 F.3d 673, 676 (2d Cir.2012). The question presented in this appeal is whether a single-floor condominium unit in a multi-story building is a “lot,” thus triggering ILSA’s protections. See 15 U.S.C. § 1703(a)(1) (statutory requirements apply to the “sale…