competitive industry and its profts 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 identifed 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 identifed 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
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