THE GROWING INFLUENCE OF COMPETITION LAW IN TOURISM The market for the sale of tourist services has been identified in the booking and sale services of tourist services (flight, hotel, car rental, etc.) which, due to their different characteristics, can each constitute a different relevant market, which could be abstractly subject to further segmentation (e.g., off-line or on-line). Nevertheless, in this case, ICA assumes that the advent of the internet has largely changed the dynamics of the sector: services whose distribution was previously the almost exclusive prerogative of traditional travel agencies are now also offered by OTAs and other entities, primarily air carrier, which, starting from the transaction for the purchase of the airline ticket, can crosssell and sell the traveler all the other tourist services he needs, making use of specialized partners. This being so, in addition to the booking and sale of airline tickets, the booking and sale of hotel services and the booking and sale of car rental services are relevant; infact this tourist services have a close connection with air transport and, moreover, Ryanair intermediate their sale on its website. According to ICA, considering the growing presence of OTAs and airlines alongside the traditional agency channel, which has led to a homogenization of the competitive conditions of these markets, at least on the national territory, and also taking into account the linguistic uniformity of the different versions of the websites of these subjects in each country, the market can be considered, as a first approximation, national ICA stressed that Ryanair DAC it seems to leverage on its dominant position in several markets of air transport sector in order to extend its market power also into the offer of other tourist services (such as hotels and car rental), harming travel agencies - both online and offline – as well as clients that buy those other services from such agencies. In particular, on the one hand Ryanair appears to impede travel agencies from directly acquiring airline tickets through their own websites; on the other, Ryanair permits traditional travel agencies to purchase airline tickets exclusively on the GDS platform, subjecting them to considerably less favorable conditions in terms of pricing, range of available services, and post-sale management of airline tickets. Ryanair's conduct seeks to restrict travel agencies from selling airline tickets, which is typically the initial step in planning a holiday and a crucial entry point for selling additional services. As such, it could have adverse consequences on both travel agencies and end-consumers, leading to a deterioration of conditions, both in terms of quantity and quality of the services, and unjustified difficulties in managing reservations.
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