Bensinger v. Scott
In Bensinger v. Scott, 625 P.2d 775, 778 (Wyo. 1981), the parties provided in one contract for a right of first refusal upon the "sale of all or any part of the first refusal property" and in a second contract one party agreed not to "sell or transfer all or any part of" the first refusal property without first offering it to the other party.
The Court held that the parties' intent in using the word "transfer" in addition to the word "sale," as well as the phrase "all or any part" in referring to the first refusal property, was more inclusive than if the parties had merely used the term "sale." Id.
The Court concluded that pursuant to this language, a non-exclusive easement, as opposed to a "sale," was sufficient to trigger the right of first refusal at issue. Id.