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that the rent required by the terms of the Second Lease Amendment
was markedly less than the rent required under the lease that
LSED executed with the Breakers in February 1984, which preceded
the execution of the Second Lease Amendment by a mere 5 months.
Respondent agrees that the terms of the 1975 Lease were more
favorable to the Mecom Group after the Second Lease Amendment
than before that amendment. Respondent maintains, however, that
our evaluation of the fair market value of the 1975 Lease cannot
be performed properly by simply comparing values of the lease
before and after the Second Lease Amendment. Instead, according
to respondent, a proper evaluation requires a comparison of the
value of the 1975 Lease with the value of several proposed leases
contained in bids entered by various cities interested in
attracting the Saints away from New Orleans. Those cities
include Phoenix, Arizona; Indianapolis, Indiana; Philadelphia,
Pennsylvania; and Jacksonville, Florida. In other words,
respondent maintains that the "market" to be considered when
determining the fair rental value of the 1975 Lease must not be
limited to the geographical boundaries of New Orleans. Instead,
it is respondent's position that the "market" must include cities
that had expressed interest in luring the Saints away from New
Orleans. Respondent maintains that information contained in
material that petitioner used in its lobbying effort indicates
that the cities of Jacksonville, Phoenix, and Indianapolis
offered free use of their stadiums in order to attract the Saints
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