CITY AND COUNTY OF SAN FRANCISCO OFFICE OF THE CITY ATTORNEY

DENNIS J. HERRERA JENNIFER CHOI

City Attorney Deputy City Attorney

Direct Dial: (415) 554-3887

Email: jennifer.choi@sfcityatty.org

May 20, 2020

Via Electronic Mail

Globe, Inc. dba Globeliving

c/o Emmanual Bamfo, CEO
“manny@globeliving.com”
“contact@globeliving.com”

Re: Violations of law at Globeliving locations in San Francisco

Dear Mr. Bamfo:

The San Francisco City Attorney’s Office has learned of Globe, Inc.’s operation of
Globeliving, a platform that links hosts and renters for hourly rentals of residential properties, “to
work & find peace & quiet from your roommates or family.” (https://globeliving.com (May 19,
2020)). The testmonials on your site also suggest that at least some of the rentals are already
occupied by residents looking to make extra income by allowing renters to use and rent their
property by the hour. Given the current COVID-19 pandemic, your operation of Globeliving at
properties located in San Francisco raises serious health and safety concerns.
Both the Governor of California and San Francisco’s Local Health Officer have
proclaimed a state of emergency due to the threat posed by COVID-19. On March 16, 2020, San
Francisco’s Local Health Officer issued a Shelter In Place Order, requiring all individuals to
remain in their homes, except to engage in essential activities. On May 17, 2020, San
Francisco’s Local Health Officer extended this order indefinitely, with some modifications.
(“Order”). The Order found that mitigation measures were still needed to combat COVID-19
because it “is easily transmitted, especially in group settings, and the disease can be extremely
serious.” A copy of the Order is enclosed with this correspondence.
Globe, Inc.’s hourly rental business appears to violate the Order as well as the San
Francisco Planning Code and chapter 41A of the San Francisco Administrative Code, which
regulate rentals of less than 30 days and accessories to a residential use.

Failure to abide by the Order is a nuisance under the San Francisco Health Code and
subject to immediate abatement. Furthermore, such failure is punishable by fine, imprisonment
or both pursuant to San Francisco Administrative Code section 7.17(b) and California Penal
Code section 148. California Penal Code section 409.5 also authorizes the City to close down
properties constituting a menace to public health. Likewise, failure to abide by the San
Francisco Planning Code is a nuisance and is punishable by fines of up to $1,000 per day.
Likewise, failure to abide by Chapter 41A of the Administrative Code is punishable by fines of
up to $484 per day.

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FOX PLAZA ∙ 1390 MARKET STREET, SIXTH FLOOR ∙ SAN FRANCISCO, CALIFORNIA 94102-5408
RECEPTION: (415) 554-3800 ∙ FACSIMILE: (415) 437-4644

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CITY AND COUNTY OF SAN FRANCISCO OFFICE OF THE CITY ATTORNEY
Page 2

Your website provides limited information as to your business’s operation. Please

provide the following information:

1. The address of each San Francisco property currently available for rent through your
platform.

2. The address of each San Francisco property where the host is also a resident of the
property.

3. Whether rentals are open to anyone, or limited to a particular category of individuals,

such as essential workers, as defined in the Order.

4. The procedures implemented by your company, if any, to protect both hosts and
renters from the transmission of COVID-19.

In the absence of this information, and without a convincing explanation of why your
business is not in violation of the Health Order, the San Francisco Planning Code, and the San
Francisco Administrative Code, you will leave this Office no choice but to conclude that your
business is operating unlawfully and subject your business as well as yourself to the above-stated
consequences. Please email Deputy City Attorney Jennifer Choi (jennifer.choi@sfcityatty.org)
with the information requested above by no later than 4:00 p.m. Friday May 22, 2020.

Thank you.

Very truly yours,

DENNIS J. HERRERA
City Attorney

/s/ Jennifer Choi

JENNIFER E. CHOI
Deputy City Attorney

Encl.

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