Sachi v. Mobil Oil Corp., 1979 U.S. Dist. LEXIS 8463, 1980-1 Trade Cases 63,044 (E.D.N.Y. 11-20-79)

§ 2802(b)(2)(C) and this section must be read independently of the terms of other sections of the PMPA. Congress did not intend to restrict the prerogative of the franchisor to exercise legitimate independent business judgment in arriving at a decision not to renew an underlying lease to the marketing premises. This is true as long as there is an arm's length relationship between the franchisor and the fee owner and there is a bona fide change in control over the premises.