(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 verifcation process’; (ii) to complete that process customers are required to follow an onerous procedure, which includes uploading a photograph of their passport or identifcation 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 verifcation 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 confdence 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 verifcation requirement, Ryanair calls OTB ‘a third party intermediary or BOT [sic]’ that is not ‘authorised’ to ofer Ryanair fights 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 verifcation requirement makes it (as Ryanair intends) very difcult for OTB properly to perform the services it ofers its customers, both before and after any completion of the online verifcation process by those customers:
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