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 fights 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 identifed by Ryanair as such to manage their bookings, or check in, online, requiring them instead to face the considerable inconvenience and time 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 fight 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 identifed 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:
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