The Second Appellate District reversed a judgment and remanded. The court held that there were triable issues of material fact as to whether, in reassessing a hotel after its sale, a county used a methodology that failed to exclude the value of intangible assets that were included in the purchase price that was paid for the hotel.

Hilton Hotels Corporation owned operated the Glendale Hilton Hotel as a full-service hotel. In June 2005, EHP Glendale, LLC, and Eagle Hospitality Properties Trust, Inc. (collectively, Eagle), purchased the hotel. Eagle’s purchase price was paid for the real and personal property, as well as for certain intangible assets and rights that included both a franchise agreement for Eagle to use the Hilton franchise in exchange for payment of a royalty and a management contract under which Hilton agreed to continue managing the hotel for two years.