prerogative of traditional travel agencies are now also offered by Online Travel Agencies (OTAs) and other entities, primarily air carriers, which, starting from the transaction for the purchase of the airline ticket, can cross-sell and sell the traveler all the other tourist services he needs, making use of specialized partners. 4.2. On 14 September 2023, ICA launched an investigation regarding an alleged exclusionary abuse of dominant position by Ryanair DAC22, the largest air carrier in Italy offering scheduled air transport services of passengers on national flights and flights to and from Italy. In a second step, ICA extended the investigation to the company Ryanair Holdings Plc, which appears to exercise a decisive influence on the company Ryanair DAC23. The investigation has been initiated following several reports received by the Authority since last May, where several associations complain that Ryanair was damaging the activity of OTAs and the interest of consumers. In ICA’s preliminary view, the alleged violation of Art. 102 TFUE concerns the markets for scheduled air passenger transport services and those, connected to the first, for booking and sales services of tourist services. Furthermore, in this case, in consideration of the large number of routes potentially affected by the conduct in question and the weight that these routes have for travel agencies, both physical and online - which, to operate profitably, must be able to offer a range of travel solutions capable of responding to the needs of the average consumer to the greatest possible extent, offering the widest choice of travel solutions both domestically and abroad – according to ICA, it is also necessary to consider the number and the range of individual routes, i.e. of the individual relevant origin-destination markets (hereinafter, O&D), which constitute all national and European connections to/from Italy. The market for the sale of tourist services has been identified in the booking and sale services of tourist services (flight, hotel, car rental, etc.) which, due to their different characteristics, can each constitute a different relevant market, which could be abstractly subject to further segmentation (e.g., off-line or on-line). Nevertheless, in this case, ICA assumes that the advent of the internet has largely changed the dynamics of the sector: services whose distribution was previously the almost exclusive prerogative of traditional travel agencies are now also offered by OTAs and other entities, primarily air carrier, which, starting from the transaction for the purchase of the airline ticket, can cross-sell and 22 See AGCM Decision, 14.9.2023, n. 30772 (A568), in Official Bulletin n. 36/23. 23 See AGCM Decision, 16.1.2024, n. 31027 (A568), in Official Bulletin n. 5/2024 156 ROSARIA GAROZZO
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