COMPETITION LAW: ONLINE TRAVEL AGENTS AND AIRLINES and its profits are thus constrained to competitive levels…competition from OTB, and the services it provides, lead to lower, not higher, prices for consumers.” (2) Ryanair attempts to prevent OTB from completing bookings on behalf of its customers. These, OTB alleges, have taken two main forms: (a) Account blocking. Once Ryanair has identified that OTB (or indeed any online travel agent) is attempting to make a booking, Ryanair prevents the agent from creating or activating a ‘myRyanair account’, which is required to make the booking. For instance, OTB has received an error message that an account has already been created with a particular email address (which is not the case), or Ryanair has not sent through the email that it normally sends when a myRyanair account is created, containing a link or code to activate the account. Without being able to create or activate the myRyanair account, OTB cannot use it to complete a booking on the OTB customer’s behalf. (b) Payment blocking. Alternatively, where OTB has been able to create and activate a myRyanair account on its customer’s behalf, Ryanair has prevented it from completing the booking at the payment stage. When OTB attempts to pay for a Ryanair booking on an OTB customer’s behalf, using an OTB credit card as described above, Ryanair’s website often reports that the booking cannot be completed, without explanation. OTB therefore believes that Ryanair may have put in place measures deliberately aimed at causing attempted payments to fail if they are identified as originating from an online travel agent. To date, OTB has sought to work around such attempts by Ryanair to prevent it from completing bookings on OTB Customers’ behalves. However, it believes that Ryanair is continuously seeking to block such workarounds and, if it can, will do so in the future. (3) Ryanair is engaged in strategies intended to degrade the experience of customers of online travel agents. It is alleged that even where, notwithstanding Ryanair’s strategies outlined above, OTB has successfully booked Ryanair flights on behalf of OTB Customers, Ryanair has engaged in further conduct intended to degrade such customers’ experience and deter them from using OTB again. In the relevant period, it is alleged that this conduct has taken two principal forms: (a) Since around December 2020, Ryanair has refused to allow OTB customers identified by Ryanair as such to manage their bookings, or check in, online, requiring them instead to face the considerable inconvenience and time
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