Sarah Prager, Competition Law - OTAs and airlines

(i) Before completion of the online verifcation process, Ryanair’s refusal to allow OTB customers to manage their bookings online applies equally to any attempt by OTB to manage such bookings on their behalves. OTB is thus prevented from making any changes to bookings that those OTB customers might request. (ii) After completion of the online verifcation process, OTB is placed in, if anything, an even more difcult position. First, the position described at (i) above continues to apply unless and until the OTB customer informs OTB of the email address supplied by them during the process (and, if necessary, any changed password). Second, in requiring OTB customers to provide a personal email address to which all future communications will be sent, Ryanair creates a situation whereby OTB may not be aware of changes to a booking (for example, a fight cancellation or change) unless the customer takes additional steps to inform OTB of that change. As customers use package holiday providers to avoid the need to manage all aspects of the holiday, this additional burden on the customer degrades the customer experience and undermines confdence in OTB. It is fundamentally at odds with the reason why OTB customers use OTB as an agent or intermediary in the frst place, as Ryanair is well aware. In the event that customers do not make OTB aware of a change, OTB would not be aware of changes to fights that require it to make amendments to other parts of the holiday: failure to make such amendments will, inevitably, degrade OTB customers’ holiday experience and further undermine trust and confdence in OTB. (4) Ryanair deliberately withholds refunds from OTB Customers. For the layperson, this is perhaps the allegation of greatest concern; and for the lawyer, it is a shocking assertion that an airline has

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