The SEC Division of Corporation Finance (the "Division") granted an exemption to a Los Angeles Rams fan club (the "Club") from having to register membership interests that the Club intends to sell. In addition to offering general membership, the Club plans to introduce paid "personal seat license" agreements that will give priority rights to fans to purchase season tickets to Los Angeles Rams home games.

In response to a request for relief by the Club, the Division agreed to rely on the Club's opinion of counsel that relevant membership interests in the Club are not securities, as classified by the Securities Act or the Exchange Act. According to the counsel of the Club:

"There are no fan club membership programs or personal seat license programs of which we are aware that have been deemed by the [SEC] to constitute the offer and sale of securities under the Securities Acts."

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