BEFORE THE 

OFFICE OF THE SECRETARY 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

In the Matter of 

 ENHANCING AIRLINE PASSENGER 

 PROTECTIONS 

) 

) 

) 

) 

) 

) 

) 

DOT-OST-2010-0140 

JOINT RESPONSE OF AMERICAN AIRLINES, CONTINENTAL AIRLINES, 

DELTA AIR LINES, UNITED AIR LINES, AND US AIRWAYS TO REPLY COMMENTS 

OF INTERACTIVE TRAVEL SERVICES ASSOCIATION 

Communications with respect to this document should be addressed to: 

 

R. BRUCE WARK 

Associate General Counsel 

American Airlines, Inc. 

P.O. Box 619616, MD 5675 

DFW Airport, TX 75261 

(817) 967-3812 

bruce.wark@aa.com 

CARL B. NELSON 

Associate General Counsel 

American Airlines, Inc. 

1101 17th Street, N.W. 

Washington, D.C. 20036 

carl.nelson@aa.com 

ANDREA FISCHER NEWMAN 

Senior Vice President – Government Affairs 

Delta Air Lines, Inc. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005 

ALEXANDER VAN DER BELLEN 

Managing Director – Government Affairs 

 & Associate General Counsel 

Delta Air Lines, Inc. 

1212 New York Avenue, N.W. 

Washington, D.C. 20005 

(202) 842-4184 

sascha.vanderbellen@delta.com

HERSHEL KAMEN 

Vice President International, Regulatory and 

Policy 

United Air Lines, Inc. 

Continental Airlines, Inc. 

1350 I Street, N.W. 

Washington, D.C. 20005 

(202) 289-6060 

hershel.kamen@coair.com 

THOMAS NEWTON BOLLING 

Managing Attorney, Regulatory Affairs 

Continental Airlines, Inc. 

1600 Smith Street, 15th Floor HQSLG 

Houston, TX 77002 

(713) 324-5606 

thomas.bolling@coair.com 

HOWARD KASS 

Vice President - Legal Affairs 

US Airways, Inc. 

1401 H Street, N.W. 

Washington, D.C. 20005 

(202) 326-5153 

howard.kass@usairways.com 

November 17, 2010 
BEFORE THE 

OFFICE OF THE SECRETARY 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

In the Matter of 

 ENHANCING AIRLINE PASSENGER 

 PROTECTIONS 

) 

) 

) 

) 

) 

) 

) 

DOT-OST-2010-0140 

JOINT RESPONSE OF AMERICAN AIRLINES, CONTINENTAL AIRLINES, 

DELTA AIR LINES, UNITED AIR LINES, AND US AIRWAYS TO REPLY COMMENTS 

OF INTERACTIVE TRAVEL SERVICES ASSOCIATION 

American Airlines, Continental Airlines, Delta Air Lines, United Air Lines, and US 

Airways hereby jointly respond to the reply comments submitted on October 28, 2010 by the 

Interactive Travel Services Association ("ITSA"). ITSA members include global distribution 

systems (GDSs) used by travel agents (Sabre, Travelport, and Amadeus) as well as online 

travel agent (OTA) websites used by consumers (Expedia, Travelocity, Orbitz, and others).1

 

ITSA’s reply comments seek government intervention on the side of GDSs against 

carriers, purportedly in the interest of protecting consumers who allegedly suffer from a lack 

of information on optional fees such as charges for checked baggage, meals and snacks, 

seat selection, and other products that carriers make available to their customers. ITSA’s 

premise is untrue. As discussed in the comments of the Air Transport Association 

previously filed in this docket, and in our own prior comments, carriers support transparency 

of fees and provide robust disclosure of optional fee information to consumers outside of 

GDS channels. ITSA is not interested in consumer welfare, but in preserving the bargaining 

power of its GDS members by taking away any leverage that carriers might have in 

 

1 ITSA’s reply comments were filed more than a month after the close of the comment 

period; if ITSA’s reply comments are accepted, the carriers’ joint response should also be 

accepted in the interest of a complete record. 
Joint Response

Page 2

negotiating lower booking fees in exchange for direct access to optional fee information. It 

is crucial to uphold the purposes of the Department’s deregulation of GDSs in 2004 by 

allowing airlines to retain a measure of bargaining power in negotiating with GDSs, resulting 

in substantial benefits that will be realized by consumers. 

While the airlines fully support disclosure of optional fee information to consumers, 

there is no need for the Department to further enhance GDS market power in order to 

accomplish this objective. Intervening in the commercial relationship between airlines and 

GDSs would undermine DOT's goals in deregulating GDSs, harming rather than advancing 

the interests of both consumers and competition. The supra-competitive GDS booking fees 

paid by the major network carriers add billions of dollars to the industry’s costs. Since this 

cost must ultimately be reflected in the price of a ticket, reducing these burdens on carriers 

and consumers should be a matter of great concern to the Department. 

I. CARRIERS SUPPORT FULL AND TRANSPARENT DISCLOSURE OF 

ANCILLARY FEE INFORMATION TO CONSUMERS 

ITSA’s accusation that carriers are hiding their fees is simply not true. The issue 

here is not transparency. Airlines agree that they should provide full information on optional 

fees directly to consumers, and they are all doing so through their websites. Carriers are in 

the business of selling air transportation, as well as optional products and services, and 

have every motivation to make information on these options readily accessible to 

consumers. Airline websites provide an excellent, cost-free way to provide information and 

booking capability on optional services and fees. Disclosure will be further enhanced 

through other aspects of the NPRM, such as requirements that e-ticket receipts list ancillary 

fees and that website home pages provide a link directly to complete information on such 

fees. In addition, carriers are developing Direct Connect systems that will enable travel 

agents to bypass GDS channels, reducing carrier costs and creating new efficiencies that 
Joint Response

Page 3

will benefit consumers. Ancillary fee schedules are widely and readily available through 

multiple channels.2

Masquerading as a consumer advocate, ITSA argues that customers who use travel 

agents to book tickets deserve "the same robust and bookable fee information as is 

provided on airline websites." While acknowledging that "robust" fee information is 

available on carrier websites, ITSA nonetheless accuses carriers of engaging in "a nondisclosure strategy" by "withholding" information from customers, "keeping fees hidden," and 

"depriving" consumers of the ability to comparison shop. 

Such claims are entirely without merit. Airline fees are not hidden. Competition for 

optional services is intense, as illustrated by Southwest Airlines’ “bags fly free” advertising 

campaign. Affinity card programs offer customers savings on checked baggage charges, 

and frequent flyers are rewarded through well-publicized loyalty programs with waivers of 

checked baggage fees and other benefits. Carriers do not want any of their customers to be 

surprised by charges for optional services, and many carriers offer discounts to customers 

who purchase these extra services, such as checked baggage, from their websites in 

advance. The airlines’ policies of consumer education, widespread publication, and 

advance discounting for optional services are all contrary to ITSA’s unfounded accusations 

of “hidden fees.” 

There are a host of other optional products that customers might want to purchase to 

enhance their travel experience, including a day pass to a club lounge, a gourmet lunch box, 

a choice seat, onboard Wi Fi, and premium video and games. These represent important 

new revenue sources for carriers, and they have a strong incentive to present and promote 

these products (including prices) to their customers. This unbundling of products is exactly 

 

2

 In addition to the efforts of the airlines to ensure that customers understand all the 

possible costs for their travel, the Department has worked to ensure transparency and full 

disclosure through the use of industry meetings and guidance letters to ensure that airlines 

fully understand the importance the Department places on transparency of cost for air travel 

to consumers.
Joint Response

Page 4

what customers have pushed for in a variety of industries and allows customers the option 

of purchasing those products of most value to them. 

The airline industry and the market for optional products is evolving toward the sales 

model pioneered by Dell Computer and other technology companies. The “basic” computer 

is available for a certain fixed price. But if the customer wants options and extras such as 

more memory, a larger display, or a faster processor, those can be purchased as add-ons. 

Today, carriers choose to make their “basic” product available through GDSs. If GDSs 

want to play a role in the emerging market for optional fee products, they will need to 

negotiate with carriers and lower their booking fees in return. 

Carriers are entitled to decide how to market their services and optional products – 

and reward distributors that are fair and efficient. GDSs are neither. Compelling airlines to 

provide their optional fee content to GDSs would harm - not help - consumers by raising 

airline distribution costs, and would directly contradict the Department’s “longstanding public 

policy affirmatively allow[ing] each airline to decide how to distribute its tickets” (Dismissal of 

ASTA Complaint, Order 2002-9-2, DOT-OST-1999-6410, September 4, 2002, p. 24). The 

Department should reject ITSA’s demand for government intervention in contract 

negotiations to require carriers to provide their ancillary fee schedules and “bookable” 

capability to GDSs without concessions from GDSs on supra-competitive booking fees. 

A. Travel Agents, Including Online Travel Agents, Have Access to 

Carrier Fee Information 

Online travel agents (and ITSA members) Expedia, Orbitz and Travelocity are not 

GDSs, but they are beholden to ITSA’s GDS members because kickbacks from high-cost 

GDS booking fees are used to subsidize OTA operations and profitability. Moreover, GDSs 

own Travelocity, Orbitz and CheapTickets. Carriers can provide the same content to OTAs 

through direct connect technology and bypass GDSs. However, because GDSs give rich 

incentive payments to OTAs for using their systems (or benefit directly through GDS 
Joint Response

Page 5

ownership of OTAs), OTAs have no incentive to use lower cost options. Carriers want to 

provide optional fee information to travel agents, but should not be compelled to do so 

through high cost GDS channels. Whether or not OTAs are accorded “bookable” 

functionality for products now sold exclusively through carrier websites or at the airport is an 

appropriate matter for commercial negotiation and will depend on whether OTAs are willing 

to use more efficient and lower cost technology provided by the carriers. 

In any event, there is no confusion today about the existence of optional fees for 

services sold through OTAs. Expedia discloses at the outset of the booking process that 

"prices do not include baggage fees and other fees charged directly by the airline." This 

clickable link calls up a detailed "airline fee chart" which invites customers "to find out who's 

charging what. From baggage handling to seat selection to food and beverages -- know 

additional flight costs before you book." The chart compares the cost of first checked bag, 

second checked bag, preferred seat selection, beverage/snack, oversize/overweight bag, 

and travel with pet and unaccompanied minor. The information is provided for 15 U.S. 

domestic carriers and 14 international carriers. In addition, a view policy link is provided for 

each carrier which takes the customer directly to that carrier's website. Orbitz has a 

prominent link at the beginning of the booking process disclosing that additional baggage 

charges may apply. This link, when clicked, calls up a chart with information on domestic 

and international baggage fees (checked and carry-on) and snacks/meals for some 70 

airlines. Travelocity discloses that airline bag fees and fees for other optional services may 

apply. This clickable link leads to a table of "airline fees" inviting customers to "compare 

fees before you buy. Planning to check your luggage? Here's a helpful chart showing the 

fees many airlines charge for the first and second checked bags. Be sure to factor in these 

extra costs when comparing flight prices." Travelocity’s chart provides information on first 

and second checked bag fees for domestic and international itineraries as well as view 

policy links that connect customers directly to the websites of some 36 airlines. 
Joint Response

Page 6

ITSA should not be heard to complain that carriers are "withholding" information. 

Indeed, the real interest of ITSA’s GDS members (and ITSA’s OTA members which benefit 

from GDS incentive payment kickbacks) is not in the information itself, but in a government 

directive that ancillary services be bookable through GDSs. That would be directly at odds 

with the core principle that the Department recognized in the 2004 final rule deregulating 

CRSs that "airlines should be free to choose to offer their webfares, or other types of fares, 

only through their own websites, without being obligated by system contracts to make them 

available through other distribution channels. Airlines can use their control over webfares to 

win better terms for CRS participation." (69 Fed. Reg. 976, 1006, January 7, 2004). 

Unfortunately, the only meaningful relief that carriers have achieved from excessive 

GDS booking fees was in the 2004 round of negotiations when carriers traded GDS access 

to webfares for an approximate 30% reduction in GDS fees. GDSs (and their captive 

agents) are now pulling out all the stops to avoid a further negotiation over content which 

could lower GDS booking fees extracted from carriers (and ultimately consumers). As noted 

above, ITSA’s reply comments state that customers using travel agents (and thus GDSs) 

"deserve the same robust and bookable fee information as is available on carrier websites." 

But rather than bargaining with carriers on ancillary fees, GDSs want the government to tip 

the scales on their behalf. That would be a very bad outcome for consumers. If GDSs are 

required to engage in contract negotiations, carriers will have a measure of leverage in 

seeking lower GDS booking fees in exchange for information on optional fees. 

B. Commercial Incentives of GDSs Are Not Aligned with the Interests of 

Consumers 

ITSA has sought to portray itself as a friend of consumers. The Department should 

not be fooled by ITSA’s posture. ITSA represents GDSs that act as intermediaries between 

airlines and their customers. Unlike airlines or travel agents (including OTAs such as 

Expedia, Orbitz, and Travelocity), GDSs do not sell airline tickets. So when GDSs claim 
Joint Response

Page 7

they are looking out for consumers, the reality is they have no vested stake in consumer 

welfare. Customers of GDSs are not consumers looking for an inexpensive ticket to go on 

vacation or to visit family. Rather, the primary customers of GDSs are large, sophisticated 

travel agencies that generate billions of dollars in travel sales through corporate travel 

accounts. The 10 largest travel agencies account for approximately 75% of GDS usage. 

Sophisticated corporate customers booking through large agencies are well informed of 

airline policies and fees. Infrequent travelers hunting for bargain fares can readily find 

“robust” fee information on the web, both from the airlines themselves and from travel 

agents to whom the airlines are willing to provide fee information directly. 

II. HIGH GDS BOOKING FEES ARE HARMING CONSUMERS AND AIRLINE 

COMPETITION 

Because of their market power, GDSs have continued to raise booking fees despite 

deep reductions in computing costs. In 1980, one gigabyte of memory cost about $700. 

Today one gigabyte costs 10 cents. Yet instead of going down, booking fees have 

continued to go up. 

While ITSA claims that the carriers' position on ancillary fees is adverse to 

consumers, what is really harmful to consumers are the supra-competitive booking fees 

exacted from carriers (and ultimately from consumers) by GDSs. Carriers pay supracompetitive booking fees to GDSs because they have limited leverage to achieve lower 

booking fees. At $3.10 per segment booked (an approximation of current industry costs), a 

roundtrip itinerary with two segments in each direction costs $12.40 in GDS booking fees. 

This results in a substantial portion of ticket revenue being diverted from the transaction 

between carriers and their customers to GDSs. And because GDSs are paid for each 

segment booked, as opposed to flown, their take is even greater. 

Excessive GDS fees distort airline competition because some LCCs – most notably 

Southwest, the largest U.S. domestic carrier – have opted out of GDS distribution. 
Joint Response

Page 8

Southwest evolved as a low cost carrier but now, because of its sheer size and presence, 

corporate customers demand that travel agents provide access to Southwest’s fares. Travel 

agents can view Southwest’s fares in GDSs, and use GDS peripheral services for 

accounting, but all bookings must be made through Southwest.com. Southwest thus avoids 

GDS booking fees and pays only a token GDS processing fee of approximately $1 for the 

entire transaction (with no segment booking fees). It is no wonder that Southwest supports 

mandatory provision of carrier content to GDSs when, under the example above, the result 

is a 12--fold cost burden exported onto legacy carriers that compete with Southwest. 

III. THE GDS MARKETPLACE IS STRUCTURALLY FLAWED AND 

NON-COMPETITIVE 

From 1985 to 2004, GDSs were highly regulated by DOT. Although these 

regulations served policy objectives at the time, they also had significant unintended 

consequences and created a market defined by GDS market power and supra-competitive 

booking fees. In deregulating the GDS industry, both the Department and DOJ expressed 

significant concerns about the state of GDS markets. 

A. DOT And DOJ Found That GDSs Exercised Market Power Over Airlines 

Leading To Booking Fees At Supra-Competitive Levels 

• DOT Final Rule on CRS deregulation (69 Fed. Reg. 976, 990, January 7, 2004): 

“We continue to believe that the systems’ fees exceed competitive levels. . . . We 

have not seen evidence that the systems’ fees generally respond to market forces, 

although two of the four have made modest concessions in exchange for access to 

airline webfares.” 

• “We find that the systems continue to have market power over airlines, as argued by 

the Justice Department; that there is some potential for conduct by the systems that 

could prejudice airline competition (most notably the sale of display bias); and that 

systems could engage in practices that could unreasonably preserve their market 

power.” (Id. at 986). 

• DOJ Comments (DOT-OST-1997-2881), June 9, 2003: “The airlines’ CRS 

divestitures leave unaffected the incentive and ability of CRSs to fully exercise their 

market power in nonstrategic ways” (p. 21) 

• “Although airline bargaining power has not in the past been sufficient to produce 

competitive booking fees, bargaining power could increase if their ability to shift sales 
Joint Response

Page 9

to the Internet and other alternative channels continues to increase. DOT should 

assess, after some reasonable period, whether the alternative distribution channels 

have continued to dissipate CRS market power.” (Id. at 21-22). 

B. DOJ And DOT Identified Misaligned Incentives As A Fundamental 

Problem In The Market 

• DOT Final Rule: “Airlines have generally been unable to persuade travel agencies to 

use one system rather than another. If they could, they would have some bargaining 

leverage against the systems. Airlines could then shift business to systems offering 

better terms for airline participants and away from systems offering poorer terms. 

Because travel agencies do not pay booking fees, they have no direct incentive to 

use the system charging the lowest fees. The record suggests, in fact, that the 

incentive payment programs used by the systems encourage travel agencies to 

choose the system that is the most expensive for participating airlines. The systems 

then obtain subscribers typically by offering to give them bonus payments. The 

revenues used for those incentive payments come from the fees paid by participating 

airlines (and to a smaller extent by other travel suppliers).” (69 Fed. Reg. at 989) 

• DOJ Comments: “DOT has not proposed a rule to remedy non-strategic supracompetitive pricing by CRSs. In the past, DOJ advocated a zero price to constrain 

both the strategic and nonstrategic exercise of CRS market power over price. We 

pointed out the advantage of a structural rule, which relies on properly-aligned 

incentives” (supra, p. 3). 

• “Travel agents and CRSs both benefit from the supra-competitive booking fees 

generated under the current structure of the market.” (supra, p. 29) 

C. DOJ And DOT Concluded That Mandatory Participation Requirements Had 

Eliminated Competition Among GDSs For Airline Content And Further 

Enhanced GDS Market Power 

 DOJ Comments: “Practices prohibited by the mandatory participation rule are 

potentially efficiency-enhancing. If an airline dealing at arms-length with its CRS 

suppliers were free to reduce its level of participation in some systems, or to induce 

agents to use a low-cost system, the airline’s bargaining power would be enhanced. 

The airline would therefore be in a better position to negotiate lower booking fees or 

drive booking toward lower cost outlets” (supra, p. 23) 

 “A low-cost distribution channel on the Internet may not offer the same level of 

functionality as a CRS, but may nonetheless be able to attract usage by travel 

agents if it has preferred access to desirable fares and inventory from a significant 

number of airlines” (supra, p. 26) 

 DOT Final Rule: “Our notice of proposed rulemaking predicted that the airlines’ 

control over access to their webfares could enable them to obtain better terms for 

system participation” (69 Fed. Reg. at 989). 
Joint Response

Page 10

 “We believe that the airlines’ ability to change their participation levels and their 

control over access to webfares is reducing the systems’ market power. Overall, 

however, we find that the systems currently still have market power over most 

airlines, although the continuing changes in airline distribution, particularly the 

growing importance of the Internet for airlines” (Id. at 990) 

Unfortunately, more than six years after CRS deregulation, the GDS market remains 

neither competitive nor efficient. The marketplace for GDS services continues to be 

structurally flawed as GDSs still pay kickbacks to travel agents to generate bookings and 

airlines still pay artificially high booking fees. Each GDS is a monopoly unto itself. Carriers 

that rely upon travel agencies for the distribution of their product must participate in each 

system, as for example participation in Sabre is not a substitute for participation in Galileo. 

The persistent ability of GDSs to charge supra-competitive booking fees is not the 

outcome that DOT expected when it deregulated the GDS industry in 2004. Prior to 

deregulation, the U.S. GDS market was divided among four systems, none of which had 

more than a 50% share, and several emerging GDSs promised to reinvigorate competition. 

Yet by 2009, the U.S. market had transformed into a duopoly, with Sabre accounting for 

60% of U.S. point-of-sale bookings and together with Travelport (which owns both Galileo 

and Worldspan) accounting for over 90%. 

IV. ACCESS TO CONTENT IS THE BEST TOOL THAT CARRIERS HAVE FOR 

NEGOTIATING LOWER BOOKING FEES 

In its 2002 NPRM on CRS deregulation, 67 FR 69365, 69380 (November 15, 2002), 

the Department found that “[t]he growing importance for many travelers of webfares, 

however, could give airlines some bargaining leverage. Airlines might obtain leverage by 

selectively giving systems access to their webfares (and perhaps corporate discount fares) 

according to the relative attractiveness of each system's prices and service quality.” Just as 

the Department favored the ability of airlines to gain leverage over GDSs by “selectively 

giving systems access to their webfares,” so should the Department recognize the 

importance of access to ancillary fee content as a matter for negotiation between the 
Joint Response

Page 11

parties. DOT’s final rule recognized the importance of increasing the bargaining leverage of 

carriers against GDSs, especially through negotiations over content: 

• DOT Final Rule: “We continue to believe that the systems’ fees exceed competitive 

levels for the reasons set forth in the notice of proposed rulemaking. We have not 

seen evidence that the systems’ fees generally respond to market forces, although 

two of the four systems have made modest concessions in exchange for access to 

airline webfares” (69 Fed. Reg. at 990) 

• “We have found that the systems continue to have some market power over most 

airlines, as explained above, although we expect that power to be diminished by the 

on-going developments in airline ticket distribution. Airlines should have some 

bargaining power against systems if each airline can choose which services and 

fares will be saleable through each system and the level at which it will participate in 

each system” (Id. at 1005) 

• “We saw a risk that systems could try to take away the airlines’ control over access 

to their fares, especially webfares, which airlines could otherwise use as leverage to 

obtain better terms from the systems” (Id. at 1006) 

• “Airlines should be free to choose to offer their webfares, or other types of fares, only 

through their own websites, without being obligated by system contracts to make 

them available through other distribution channels. Airlines can use their control 

over webfares to win better terms for CRS participation” (Id.) 

• “More importantly, the [mandatory participation] rule limits the ability of owner airlines 

to bargain for better terms with the systems. If such an airline could credibly threaten 

to reduce its participation level in a system, it would have some leverage for 

obtaining lower fees or better service. The rule eliminates that option. As the Justice 

Department states, if the rule is eliminated, ‘‘the airline would therefore be in a better 
Joint Response

Page 12

position to negotiate lower booking fees or to drive bookings toward lower-cost 

outlets” (Id. at 1009) 

V. DOT CAN PROMOTE THE DEVELOPMENT OF LOWER COST 

ALTERNATIVES TO GDS’S BY REFRAINING FROM RE-IMPOSING 

WHAT WOULD AMOUNT TO A MANDATORY PARTICIPATION RULE 

FOR AIRLINE CONTENT 

The Department should encourage the development of new, lower cost alternatives 

and refrain from further empowering GDSs by giving them mandatory access to airline 

content. Direct Connect and other options that have the potential to provide relief to carriers 

and consumers could be defeated if GDSs prevail in this proceeding. Rather than 

welcoming new ways to get information into the hands of consumers, GDSs have denied 

third party technology companies the “preferred provider” status GDSs unilaterally require to 

develop products that they deem compatible with GDS and travel agent systems. GDSs are 

at the center of most travel agency IT systems, and GDSs have used this position to impede 

the development of peripheral IT systems, such as user interfaces or customer service or 

accounting systems. 

VI. CONCLUSION 

For the foregoing reasons, the Department should decline to mandate the provision 

of optional fee information by carriers to GDSs. Access to content is one of the few 

bargaining chips available to compel GDSs to reduce their unreasonably high fees. By 

requiring GDSs to negotiate for optional fee data, the Department will be acting in the 

interests of consumers who stand to benefit from lower fares that would be made possible 

by lower GDS booking fees. 
Joint Response

Page 13

Respectfully submitted, 

CARL B. NELSON 

Associate General Counsel 

American Airlines, Inc. 

THOMAS NEWTON BOLLING

Managing Attorney, Regulatory Affairs 

Continental Airlines, Inc. 

ALEXANDER VAN DER BELLEN 

Managing Director – Government Affairs 

 & Associate General Counsel 

Delta Air Lines, Inc. 

 

HOWARD KASS 

Vice President - Legal Affairs 

US Airways, Inc. 

November 17, 2010