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,
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