INTERNATIONAL JOURNAL OF TOURISM, TRAVEL AND HOSPITALITY LAW costs of checking in at the airport. When OTB customers thus prevented from checking in online by necessity checked in at the airport, Ryanair in some cases purported to charge them additional fees (in the sum of €55 per person per flight leg) for doing so. Ryanair has since claimed that the imposition of such charges was inadvertent, but OTB clearly does not accept that this is the case, given the background relations between the businesses. Until the beginning of July 2021, this refusal to provide online services was absolute; however, from 2nd July 2021, rather than simply refusing to allow OTB customers identified by it as such to manage their bookings, or check in, online, it is said that Ryanair introduced a new (and ongoing) course of conduct, whereby: (i) it tells OTB customers that they will not be permitted to manage their bookings, or check in, online, without going through a so-called ‘online verification process’; (ii) to complete that process customers are required to follow an onerous procedure, which includes uploading a photograph of their passport or identification card, providing a video of their face, providing a personal email address (to which all future communications will be sent), and paying a 35 euro cent fee; and where such an OTB customer chooses not to undertake the online verification process, Ryanair continues to refuse to allow them to manage their booking, or check in, online, OTB contends that these onerous requirements are a breach of the airline’s obligations to its customers. Furthermore, it says, whilst imposing them, Ryanair has further sought to undermine its customers’ trust and confidence in OTB; when informing customers that they are unable to check in online and when they do eventually check them in at the airport, Ryanair has informed them, wrongly, that they are entitled to a lesser consumer experience than other customers who have booked directly with the airline. In addition, when informing OTB customers of its online verification requirement, Ryanair calls OTB ‘a third party intermediary or BOT [sic]’ that is not ‘authorised’ to offer Ryanair flights for sale, and suggests to customers that OTB may have imposed ‘massive mark-ups’ on top of Ryanair’s own prices. OTB contends that Ryanair’s imposition of the online verification requirement makes it (as Ryanair intends) very difficult for OTB properly to perform the services it offers its customers, both before and after any completion of the online verification process by those customers: (i) Before completion of the online verification process, Ryanair’s refusal to allow OTB customers to manage their bookings online applies equally to any
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