### BEFORE THE DEPARTMENT OFTRANSPORTATION WASHINGTON, D.C. Application of 

### PRIMERAAIRSCANDINAVIAA/S for a foreign air carrierpermitpursuantto 49 U.S.C. 

### §41301 and for exemption authority pursuantto 49 U.S.C. 

### §40109 (U.S. -EU Scheduled and CharterAirTransportation) ) ) ) ) DocketDOT-OST-2014-0125 ) ) ) ) ) 

# ____________________________________) ANSWEROF SCANDINAVIANAIRLINES SYSTEMTOTHEAPPLICATION OF PRIMERAAIRSCANDINAVIAA/S FORAN EXEMPTIONAND FOREIGNAIR CARRIERPERMIT Communications withrespectto this document should be addressed to: Hans Ollongren Head ofPublic and RegulatoryAffairs SCANDINAVIANAIRLINES SYSTEM STODX SE-195 87 Stockholm, Sweden

Date: August 5, 2014 Michael F. Goldman SILVERBERG, GOLDMAN

& BIKOFF, L.L.P. 1101 30th Street, N.W. Suite 120 Washington, D.C. 20007 Tel: (202) 944-3305 E-Mail: mgoldman@sgbdc.com Counsel for SCANDINAVIAN AIRLINES SYSTEM (SAS)BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. 

### Application of PRIMERAAIR SCANDINAVIAA/S 

### for a foreign air carrierpermitpursuant to 49 U.S.C. 

### §41301 and for exemption authority pursuantto 49 U.S.C. §40109 (U.S. -EU Scheduled and CharterAir Transportation) ) ) ) ) ) ) ) ) 

# _____________________________________) DocketDOT-OST-2014-0125

ANSWEROF SCANDINAVIANAIRLINES SYSTEM TO THE APPLICATION OF PRIMERAAIR SCANDINAVIAA/S FORANEXEMPTIONAND FOREIGNAIR CARRIERPERMIT 

### Scandinavian Airlines System ("SAS" or "Scandinavian Airlines") hereby submits this answer to the application by Primera Air Scandinavia A/S ("Primera") for exemption authority under 49 U.S.C § 40109 and a foreign air carrier permit under 49 U.S.C. § 41301. SAS objects to Primera's application to the extent that grant ofthe requested exemption authority arid foreign air carrierpermit would permit Primera to hold out services to and from the United States in the name "Air Scandinavia" or "Scandinavia Air." Primera's potential use of either ofthese trade names, which are almost identical to that ofScandinavian Airlines, to initiate, among other things, service to the United States will cause consumer confusion between the two carriers' services. Thus, SAS requests that any exemption authority and foreign air carrier permit issued to Primera be expressly conditioned on the requirement that the carrier will not hold out service to and from the U.S. in the name "Air Scandinavia" or "Scandinavia Air." The Department ofTransportation ("Department") has long recognized its responsibility to safeguard the public from such confusion, and the Department has the power to take action ifthere is evidence of a significant potential for, or of actual, public confusion. 14 C.P.R. 

### §215.2.

### Answer ofScandinavian Airlines System August 5, 2014 Page 2 Primera's application warrants such action because the evidence of potential consumer confusion is great. Primera may take the position that it is permitted to hold out service as Air Scandinavia, ScandinaviaAir orPrimera Air Scandinavia. 1 

### The application is silent onhow exactly Primera plans to hold out service on its new U.S. flights. For over 65 years, however, the Scandinavian Airlines' name has represented high-quality airline service to and from Scandinavia. The value ofthe name represents the dedication ofScandinavian Airlines' employees to providing superior service as well as millions ofdollars in investments in marketing and promotion. Use of the "Air Scandinavia" or "Scandinavia Air" name by Primera would be an obvious attempt to capitalize on SAS's name, as "Air Scandinavia" and "Scandinavia Air" consists basically ofthe same two words as Scandinavian Airlines- "S,candinavia" plus "Air" or "Airlines"-- with obvious visual, aural and connotative similarities. SAS has used the "Scandinavian Airlines" name in the United States since shortly after the end ofWorld War II; a copy ofthe corporation and business entity database entry from the New York State Division of Corporations website showing use of the corporate name "Scandinavian Airlines System, Inc." beginning on September 16, 1946 and "Scandinavian Airlines of North America, Inc." beginning on April 25, 1980 is included as Attachment A hereto. SAS also

1 

### 14 C.P.R. § 215.3 requires that in holding out to the public and in performing air transportation services, a foreign direct air carrier is permitted to use only the name in which its operating authority is issued or trade name is registered. However, the rule permits "[m]inorvariations in the use ofthis name, including abbreviations, contractions, initial letters, or othervariations ofthe name that are identifiable with the authorized name[.]" SAS maintains that the use by Primera ofthe names "Air Scandinavia" or "Scandinavia Air" would not constitute such a "minor variation" and therefore would be prohibited by Part 215 ofthe Department's Regulations. Nevertheless, for the sake of clarity and to avoid the potential for public confusion, SAS requests that DOT expressly condition any grant ofthe Primera application on the requirement that it will not use either ofthese names inholding out its U.S. services.

### Answer ofScandinavian Airlines System August 5, 2014 Page 3 advertises and markets the "Scandinavian Airlines" brand extensively in the US; examples ofsuch advertisements and marketing efforts are provided in Attachment B hereto. Importantly, use ofthe "Air Scandinavia" or "ScandinaviaAir" name byPrimera would lead to immediate confusion in the primary medium used by consumers for shopping today for air travel -the Internet. When the words "Scandinavia Air" or "Air Scandinavia" are entered as search terms in Google, the first results returned refer to Scandinavian Airlines and its services. These Google search results are discussed in more detail in Section II.A. below. It 

### is precisely to avoid such confusion that Part 215 exists. Accordingly, the Department should expressly condition the grant ofany exemption authority and foreign air carrier permit to Primera on the requirement that the carrier shall not hold out service to and from the U.S. in the name "Air Scandinavia" or "ScandinaviaAir."

I. · TheDepartmentHas Adopted Standards to Protect Consumers from Confusion. 

### To ensure that constimers are not confused by carriers using similar names the Department adopted Part 215. As noted above, certificated air carriers, commuter air carriers, and foreign direct air carriers may not operate orhold out to the public air transportation services in aname that is not registered with the Department. 14 C.P.R. § 

### 215.3. After a carrier attempts to register its name,2 

### the Department notifies the applicant ofany other certified, foreign or commuter carriers that may have an identical or similar name, and the applicant must notify the identified carriers of its registration. 14 C.P.R. § 

### 215.5. The applicant's notification must "identify the applicant and state its proposed name or the name requested, area ofoperation or proposed area ofoperation, type of business, and other pertinent matters." !d. 

### The Department reserves the discretion to intervene

2 

### "Department
...construe[s] any application for initial, reissued, or transferred authority as containing a 'registration' ofthe intended name." 14 C.P.R. §

### 215.4(a).Answer ofScandinavianAirlines System August 5, 2014 Page4 where there is "evidence ofa significant potential for, or ofactual, public confusion." 14 C.P.R. § 215.2. Ofcourse, the Department has not hesitated to protect consumers from confusion when the circumstances warrant it.3 Under its precedents, the Department evaluates certain key factors that might cause confusion when adjudicating disputes regarding trade names,4 including (a) the similarity of the names and the relative strength of the existing carrier's name, (b) any geographical overlap in operations, and (c) the type ofoperations ofthe two carriers. Consideration ofeach ofthese factors demonstrates that Primera's use ofthe name "Air Scandinavia" or "Scandinavia Air" would cause consumerconfusion.

II. TheAir Scandinavia and ScandinaviaAirNames Will Cause Consumer Confusion A. Given the Similarity ofthe Air Scandinavia and ScandinaviaAir Names to Scandinavian Airlines' Well-Established Brand Name, Consumer Confusion is Inevitable. There is no doubt that Primera's use ofthe name "Air Scandinavia" or "Scandinavia Air" would confuse the public. As is obvious, the name "Air Scandinavia" and "Scandinavia Air" contain basically the same two words as "Scandinavian Airlines"

-- the order simply is reversed. The words "Scandinavia" or "Scandinavian Airlines" are however inextricably linked to SAS inthe minds ofthe traveling public. This recognition has resulted from Scandinavian Airlines over 65

3 

### See In the Matter ofthe Trade Name Issued to Hyannis Air Service, Inc. d/b/a Cape Air d/b/a NantucketAirlines, Order to Show Cause Concerning Name Similarity, Order 2006-6-36, Docket OST-2006-25256 (June 28, 2006) (hereinafter

### Hyannis Order); In the Matter of Airpac, Inc., Order onReview ofStaffAction, Order 83-5-38, Docket 40865, 101 C.A.B. 520 (May 4, 1983) (denying Airpac, Inc.'s application for name change to Air Pacific Airlines, Inc. because there would likely be confusion with AirPacific Limited) (hereinafter

### Airpac Order) 4 

### See In the Matter of Airpac, Inc. Name Change, Order Granting Name Change and Reissuing Certificate, Order 82-11-7. Docket40865, 98 C.A.B. 158 (Nov. 2, 1982), 

### rev'dOrder on Review of StaffAction (May 4, 1983) (denying application ofAirpac, Inc. to use name Air Pacific Airlines, Inc. because ofconfusion withAirPacific Limited).

### Answer ofScandinavian Airlines System August 5, 2014 Page 5 year history ofoperating under the "Scandinavian Airlines" name. See 

### Attachment A. During this time, Scandinavian Airlines has marketed extensively and developed relationships with numerous codeshare partners that display SAS's code on flights to and from countries in Europe and Asia, as well as inthe United States. SAS transported approximately 28 millionpassengers in 2013. SAS has invested heavily in the advertising and promotion ofits "Scandinavian Airlines" brand across all types ofmedia as the advertising examples in Attachment B demonstrate, and, as a result, the public has come to associate the name with services emanating exclusively from Scandinavia. Scandinavian Airlines' customers will be confused by Primera's service in the United States were it to use the "Air Scandinavia" or "Scandinavia Air" name. Despite Primera's comparatively limited presence on the Internet, its U.S. services will cause consumer confusion in the U.S. as the Google results belowusing the search terms "Air Scandinavia" demonstrate. Figure 1: Google SearchResults for "AirScandinavia"

Scandinavian Airlines- F!y Scandlnavla"s leading alrtine WA

**w~wiJ.;,.as~~;** ..

**B¢{)!ur:f.1>~·'!0vil**

ftJ to

**S~oclthc:m** (!-.RNl f!JfOfJI'f!$M H!to Ccpenh3gt<o {CPH} nytoSt.war.gf!r Fly Scandinavian Airlines- OneTravel.com t.Z1

**scaudifllsviau-.aidint:::>.on~:!ral>!e:l.aJ!!!f** ...

**Cht~.rp** Scandk:allian Alr

**R~:!Hll\'<.!:i,m** l.:1W F;;n Pr;;m:se. Bo:1!-: &S!!H N:>w! IJ<Jy

**~>.rh!": Con!M~~H:•J**  . S-T.& ;mdSt·wro

**Ho~:!-i:1g** ... Pay Less ;m<:! f!"3\'t:i

**Mo1~** Ra!ings :ru<.'i!<

**!:1~0** ,:,;1C
.. r

**:;,~:;** (\;1G SAS: Flights to Sweden. Norv.>ay ant: Denmark
...

**Y<W:>t.!\'y<~.C'Df'JJeniusJ** .. **S~.'lr:i.l~M~aroA~1:r:l,~;.** y

**W~kcme**I¢ lht:

**of.~<:i<Ji** $/>.$ 1 J;)

**:.>~eb:,f!~** f:trd l!":ft

**~,;:;t** !ii<.jhl 114'\!.?it>'::' (l<;;l"t

**~~~':'US\\!** S<:aHdinaviB wil.h Hl>

**o:t!~'lii.** s;:.,s

**oif-~n-:**yms

**it:~w** bro:;

**!~ ~:il**  **hm~** ..

SAS SAS<Jf:ef'::'clleaptligtM-1¢ S::.i'!r.din;;\'liJ, f.L:rilj%',1\t.\a :u:d
... Flight status SA!;: SC<l(l'.ilni'l'>'\an

**Ai!lir.~** S•">t.:m

**{l~A.** (':ffir:!a! SA:'>

**t->~'>ll•1:fl;;~ian** .. Online

**check.~in** ()'licia\ SA.S Sccw.:li:l<:vi:sr-

**Ajrl~J~:"I** Ur:l:M K:r:g<lr.m

**W¢~r.<lii** Denmark, Norway. Sweden W.;:wrr:<:< tG

**S-:a:;dir:a~i<>'l** Ai<iines J;:;par.wi't:.s!:e.ii'ldlhaiawl!'>t

... Scandinavian Airlines

**C....:;m<iina~<iafl** ..&.lf:!nils cr SAS. previooslt

**St:imdina~aaAiliif>;)S** Syt;!mn. is the

**fi~g** carrier <>!Oeu:ndfr.,

**Nt~!W.l)',** amJ Swe!k!l, uud l.he

**large-:.tc:~Mo:!in~Bnmn6vis** WW.ipe<.i\a Foundtrd:Att>.}i!5f 1,1946

**Cu~rserv!r.e:1(660).?11-.?.150** 

# IIJ

Fountfers:

**Nmw~iar1** A.'rU!;es,

**Swedisl11nl;m::cn!lm~ntal** AlJiin*l. Oaoi$bAirUnes

**~~~~~ ~~~~~--~t-~~~s**  1

**E:::mrfli~,:l;t:"JI.'•ll!"!U 1r~ti>:Higlll**  People also search for

**:.;;*"'~;;;**.. :"flo:<;

**NOIW~'Jian** Lt.E!:he:1sa Fi:ln<>il KLM

**AirS!J~Jitle**

**"'""~"100%''··:;;·····**

### Answer ofScandinavian Airlines System August 5, 2014 Page 6 These search results for "Air Scandinavia" depicted above have troubling implications for consumers. They show that Scandinavian Airlines appears in the top three search results, and as shown in Attachment C, Primera comes up far down on the list. The nearly-identical name and search results will lead consumers to believe that Primera is affiliated with SAS and will offer the same type and level ofservice as ScandinavianAirlines. Butthere can be no assurance ofPrimera's service quality, leading to ill-informed purchase decisions. Moreover, customers seeking additional information about Primera or its service offerings will be directed to the Scandinavian Airlines website and customer service operation, which would not be able to provide the customer with assistance. Such episodes would frustrate the traveling public and damage SAS's reputation for providing helpful customer service. Attachment C sets out the full Google search results for "Air Scandinavia" as well as the similarresults for "ScandinaviaAir." B. Confusion Will Result from the Geographic Overlap between Scandinavian Airlines' and Primera's Operations. 

### Primera's proposed transatlantic operations invariably will overlap with Scandinavian Airlines' operations. SAS currently offers transatlantic nonstop flights betweenNew York/Newark, Washington, Chicago, Houston5 

### and San Francisco and Scandinavia, and codeshare flights on Star Alliance Partner United from a number ofother U.S. cities. While Primera's application does not indicate which U.S. cities it plans to serve with its U.S.-Scandinavia flights, any service from a city on the U.S. East Coast, the Midwest or on the West Coast will involve geographic overlap with SAS's existing services. Whether the services ofsimilarity-named carriers overlap is an important consideration in the Department's consideration ofwhether consumer confusion is likely. 6 

### Indeed,

5 

### Effective August 20,2014. 6Hyannis Order 

### at 2 (revoking name registration because "both air carriers intend to operate in the same geographic region").Answer ofScandinavianAirlines System August 5, 2014 Page 7 the Department's predecessor agency, the Civil Aeronautics Board, rejected a petition for a name change due to the possibility ofconsumer confusion where "there [wa]s a significant potential for geographical overlap."7 In its application, Primera requests authority to conduct extensive U.S.-Europe scheduled and charter operations that will overlap with ScandinavianAirlines' existing operations, including: Foreign scheduled and charter air transportation ofpersons, property and mail from any point or points behind any Member State ofthe European Union, via any point or points in any Member State and via intermediate points, to anypoint orpoints inthe United States and beyond.8 The geographic area for which Primera requests DOT authority overlaps with the geographic area of the U.S.-Scandinavia services the public may purchase from Scandinavian Airlines. This is muchmore than a "significantpotential" for geographic overlap. The grant ofPrimera's application will result in actual overlapping operations that will inevitably result in consumer confusion were it to use eitherthe "Air Scandinavia" or "ScandinaviaAir" names.9 Finally, the livery of Primera's aircraft if it uses the name "Air Scandinavia" or "Scandinavia Air" painted on the aircraft fuselage would lead to public confusion. SAS operates twin-engine Airbus A330 and A340 aircraft that carry the "Scandinavian Airlines" livery. Primera proposes service with twin-engine B-737-NG aircraft. While Primera's current livery is distinguishable from that of Scandinavian Airlines (see Attachment D, photos ofSAS and Primera aircraft livery), SAS has no way to know whether Primeraplans to use different livery for its U.S.- EUtransatlantic services. Whatis clear is that both companies will operate their U.S. services with

7Airpac Order at 2. 8 Appl. ofPrimeraAir ScandinaviaA/S ForA Foreign Air Carrier Permit and Exemption Authority at 3 (July 21, 2014). 9Airpac Order at 2.Answer ofScandinavianAirlines System August 5, 2014 Page 8 twin-engine overwater aircraft, and the potential exists for public confusion were Primera to use an "Air Scandinavia" or "ScandinaviaAir" livery on its U.S. flights. 

### III. To Avoid Consumer Confusion, the DepartmentMust Condition Primera's Exemption and Foreign Air CarrierPermitApplications The Department should exercise its authority to prevent Primera from introducing transatlantic services into the United States that will confuse the public. The Department has authority under 49 U.S.C. § 41712 to ensure that the public is not subject to any unfair or deceptive practices orunfair methods ofcompetition. Moreover, the Department should exercise its authority to intervene when a proposed name has a significant probability ofcausing consumer confusion. The Department and the CAB have done so in circumstances where the possibility of consumer confusion was far less than presented by Primera's application. In the Matter of Airpac, Inc., the CAB ultimately concluded consumer confusion was likely even though there was no geographical overlap

- unlike the case here where there will be actual geographic overlap

-- between carriers operating in Fiji and Alaska at the time ofthe decision. Despite the apparent disparate operations, the CAB concluded that confusionbetween "AirPacific" and "AirPacific Airlines, Inc." was likely because (a) the two names were substantially identical; (b) there was "a significant potential for geographical overlap" 10; and (c) the name "AirPacific" was identified with the services providedby the Fiji carrier by consumers after years ofmarketing efforts. 11 Consequently, the CAB denied the application ofthe Alaskan carrier to change its name. Far beyond what the Fiji carrier had done in the Airpac case, SAS has spent an incredible amount ofmoney and over 65 years to develop an extensive network of routes and a preeminent "Scandinavian" brand. As a result of these

10 Air Pacific Limited held authority to serve several northwestern U.S. points and indicated that it intendedto use that authority and would likely advertise in areas where Airpac operated. 11Airpac Order at 2.

### Answer ofScandinavian Airlines System August 5, 2014 Page9 investments as well as its commitment to superior service, the public and trade have come to associate with name "Scandinavian" with quality services emanating exclusively from SAS. Primera's application and potential use of the "Air Scandinavia" or "Scandinavia Air" names would co-optthose names and devalue the investments SAS has made to the detriment ofthe traveling public who are likely to believe the companies are affiliated and as a result make ill

### informed purchase decisions. Ifthe Department fails to act in this case, it will signal to the airline industry that investments in quality and name recognition can be degraded and undermined by subsequent entrants using similar names. This is an unacceptable result, and contrary to the numerous occasions where the Department has acted to protect such investments and prevent such consumer confusion. 12 

### Because the initiation of transatlantic flights by Primera using the "Air Scandinavia" or "Scandinavia Air" brand would cause immediate confusion to the public and harm, SAS requests that the Department expressly conditionthe grant ofany exemption authority and foreign air carrier permit to Primera on the requirement that the carrier will not hold out service to and from the U.S. inthe name "Air Scandinavia" or "ScandinaviaAir."

12 

### See Airpac Order (denying Airpac, Inc.'s application for name change to Air Pacific Airlines, Inc. because there would likely be confusion with Air Pacific Limited); 

### In the Matter of At!. Express, Final Order, Order 93-1-51. 99 C.A.B. 

### 621 (Jan. 14, 1983) (finding reasonable likelihood that public confusion would result between Atlantic Express, Inc. and Atlanta Express Airline Corp.); 

### Air Specialties Order (finding that public confusion would result from Orion International Airlines, Inc. and Orion Air).Answer ofScandinavian Airlines System August 5, 2014 Page 10 WHEREFORE, SAS respectfully requests that the Department expressly condition the grant of Primera's application for an exemption and foreign air carrier permit on the requirement that Primera shall not hold out its services to and from the United States in the name "Air Scandinavia"
or "ScandinaviaAir," and for such other or further reliefas it deems appropriate and consistent with the public interest.

Dated: August 5, 2014 Respectfully submitted,



# ~£~-u.A Michael F. Goldman



# ~ L. Jeffrey Johnson SILVERBERG, GOLDMAN & BIKOFF, LLP 1101 301 H St., N.W., Suite 120 Washington, DC 20007 (202) 944-3305 Counsel for SCANDINAVIAN AIRLINES SYSTEM (SAS)ATTACHMENT AEntity Information Page 1 of2 

# NYS DepartmentofState
Division ofCorporations Entity Information The information contained inthis database is currentthrough July 29,2014. SelectedEntityName: SCANDINAVIANAIRLINES OF NORTHAMERICA INC. SelectedEntity Status Information 

### CurrentEntityName: SCANDINAVIANAIRLINES OF NORTHAMERICA INC. 

### DOS ID #: 59792 

### InitialDOS FilingDate: SEPTEMBER 16, 1946 

### County: NEW YORK 

### Jurisdiction: NEWYORK 

### EntityType: DOMESTIC BUSINESS CORPORATION 

### CurrentEntity Status: ACTIVE SelectedEntity Address Information 

### DOS Process (Address to which DOS will mailprocess ifaccepted on behalfofthe entity) NATIONAL CORPORATE RESEARCH, LTD. 10 E. 40TH STREET 10TH FLOOR NEWYORK, NEWYORK, 10016 

### ChiefExecutive Officer MR. STEFAN LARSSON C/0 SAS 9 POLITO AVENUE LYNDHURST, NEWJERSEY, 07071 

### PrincipalExecutive Office SCANDINAVIANAIRLINES OF NORTHAMERICA INC. C/0 SAS 9 POLITO AVENUE LYNDHURST, NEW JERSEY, 07071 

### Registered Agent NATIONAL CORPORATE RESEARCH, LTD. 10 E. 40TH STREET 10TH FLOOR NEW YORK,NEWYORK, 10016_ 

## •Entity Information

This office does notrecord informationregarding the names and addresses ofofficers, shareholders or directors ofnonprofessional corporations except the chiefexecutive officer, ifprovided, which wouldbe listed above. Professional corporations must include the name(s) and address(es) ofthe initial officers, directors, and shareholders inthe initial certificate ofincorporation, howeverthis information is notrecorded and only available by viewing the ce1iificate.

*StockInformation 

### # ofShares Type ofStock $ Value per Share 0 Capital Stock 175000 *Stock informationis applicable to domestic business corporations. Name HistoryEntity Name Page 2 of2

Filing Date Name Type APR25, 1980 Actual SEP 16, 1946 Actual SCANDINAVIAN AIRLINES OF NORTHAMERICA INC. SCANDINAVIAN AIRLINES SYSTEM, INC. A Fictitious name mustbe used whenthe Actual name ofa foreign entity is unavailable for use in NewYork State. The entity mustuse the fictitious name when conducting its activities orbusiness in NewYork State. NOTE: NewYork State does notissue organizational identification numbers.
Services/Programs



### • Search Results New Search Privacy Policy 

### I Accessibilitv Policy 

### I Disclaimer 

### I Return to DOS Homepage 

### I Contact UsATTACHMENT B



### •

# II 

# Our Late Flight NewarkCopenhagen is back.

AlwayswithSAS SK902 departs Monday,Wednesdayand Thursdayat 11:30pm Business, Economy Extra, Economy 60destinations in Scandinavia: EuroBonus points Scandinavian Airlines flysas.com/us A STAR ALLIANCE MEMBER

**v~.,:"'**SAS Plus Benefits: Separate cabin 1More legroom 1Moreseat recline Widerseatw/leg rest 

### I Upgraded meals 

### IVideo on demand 2checked bags 12carry-on bags Priority boarding 

### I Prioritybaggage SAS loungeaccess 

### flysas.com/us *Upgrade is Freefor infants. Subjecttoavailabilityofmeals. EB pointsaccordingtooriginalticketed booking class. Notavailableforaward tickets. 

# 1111
Scandinavian Airlines A STAR ALLIANCE MEMBER

**v~-**ATTACHMENT CAAA) Ifsearch term is Air Scandinavia:

Anytime Past hour Past24 hours Past week Past month Past year All results Verbatim Web Images Videos News Shopping Maps Books About 8.820.000 results Scandinavian Airlines -Flywith Scandinavia's leadingAirline

**~~~~ w~WJ.flysas.comi**  ... Book your flight here! SA.S has 4.071 followers on Google+ Flyto Copenhagen (CPH) Flyto Stockholm (ARN) Flyto Oslo (OSL) Fly to Gothenburg Flv Scandinavian Airlines- OneTravel.com

**~~]** scandinavian-airlines.onetravel.com/ • 4.0 *****ratingfur onetravel com Book Cheap Flights On Scandinavian UpTo $15 Off Fees. Save Big Now! OneTravel has 535 followers on Google+

SAS: Flights to Sweden, Norway and Denmark- ScandinavianAirlines www.flysas.com/enlusi ,.. Welcome tothe official SAS USwebsite. Find the best flight bargains from the US to Scandinavia with us online. SAS offers you low fares to and from
. SAS SAS offers cheap flights to Scandinavia, Europe; Asia and Flight status SAS Scandinavian Airlines System USA Official SAS Scandinavian
... More results from flysas.com » Online check-in Official SAS Scandinavian Airlines United Kingdom website
... Denmark. Norway. Sweden \Nelcome to Scandinavian Airlines Japan website, find the lowest
___ SunAirof Scandinavia- Wikipedia. the free encyclopedia en.wikipedia.orglwiki/Sun_ Air_ of_Scandinavia ,.. Sun Air of Scandinavia (trading as SUN-AIR) is an airline based in Billund, Billund Municipality, Denmark. It is a regional scheduled airline operating afranchise
___ ScandinavianAirlines - Wikipedia, the free encvdopedia en.wikipedia.orglwikilScandinavian _Airlines ,.. Scandinavian Airlines or SAS, previously Scandinavian Airlines System, is the flag
... Source: ICAO Digest of Statisticsfor 1950-55, lATA World AirTransport
...Scandinavian Airlines- StarAlliance WNIN.staralliance.com!enlaboutlairlines/scandinavian_airlinesf • Scandinavian Airlines is Northern Europe's leading airline with close to 800 daily flights to 120 destinations in Scandinavia, Europe. the U
..S. and Asia. Scandinavian.net www.scandinavian.netl • SAS Sverige. SAS ar Skandinaviens ledande flygbolag och erbjuder flygresor till over 100 destinationer varlden over. SAS ingar i natverket Star Alliance,.,.
__ PrimeraAir ';VVIW_primeraai
_ m! "' rvly Reservation: Do no e Scandinavian characters such as A, A, 0 and 0
__ Terms and Conditions - Privacy Policy. 2014 Primera AirAll Rights Reserved
___ SAS Sweden- SAS www.sas.selenl • Sas.se -find cheap

**airl'~ne** tickets

**online.~** ffer cheap flights to and from Scandinavia, Europe, Asia and North America_ Book your flig Searches related toair scandinavia air scandinavian swiss air sun air ofscandinavia baggage allowance primera air scandinavia a/s

BBB) Ifsearch term is Scandinavia Air sas reservationsAny time Past hour Past 24 hours Past week Past month Past year All results Verbatim ; scandinavia air

Web Images Videos News Shopping Maps Books A.bout 3 930,00() results ScandinavianAirlines - Fly with Scandinavia's leadingAirline

**&~4~** ww.v.flysas.coml • Book your flight here1 SAS has 4.071 followers on Google+ Fly to Copenhagen (CPH) Fly to Stockholm (ARN) Fly to Stavanger Fly to Oslo (OSL) ScandinavianAirlines- Double Up - orbitz.com

**t~li** www.orbitz.com/Scandinavian-Airlines • Earn On Top Of Miles With the Orbitz Rewards VISA Card ScandinavianAirlines - Find Cheap FlightTickets & Save

**[\;;J{~** W\'YI.'V.cheaptickets.com/ "' Book NowWith Cheaptickets® 

# -

SAS: Flights to Sweden, Norway and Denmark- ScandinavianAirlines \'1/VilW.flysas.comten/usJ • SAS offers you lowfares to and from Scandinavia and to the whole world
.. SAS SAS offers cheap flights to Scandinavia, Europe, Asia and
... Online check-in See ifyour flight is eligible for online check-in. •Also applies
... More results from flysas.com » Flight status Flight status. Airport, Flight number, Arriva.ls. Departures. Yesterday
___ Special offers Specia.l offers
.. Book great lowfares in SAS Business to ... ScandinavianAirlines- Wikipedia, the free encyclopedia en.wikipedia.orgfwiki/Scandinavian_Airlines ,.. Scandinavian Airlines or SAS, previously ScandinavianAirlines System, is the flag
___ Source: ICAO Digest of Statistics for 1950-55, lATA World AirTransport
___ Scandinavian.net www.scandinavian.netl

... SAS Sverige. SAS ar Skandinaviens ledande flygbolag och erbjuder fly·gresor till over 100 destinationervarlden over. SAS ingar i natverket StarAllianceTM. ScandinavianAirlines- StarAlliance www.staraUiance.comlenlaboutlairfines/scandinavian_airHnes/

... ScandinavianAirlines is Northern Europe's leading airline with close to 800 daily flights to 120 destinations in Scandinavia, Europe, the U.S. and Asia.SAS Sweden - SAS \I'J\N'N.sas.seien!

... Sas.se- find cheap airline tickets online. We offer cheap flights to and from Scandinavia. Europe, Asia and North America. Book yourflight tickets today on __ SAS Cargo is the leading aircargo carrierto. from, via and within ··- \1\1\'1\"'
..sascargo.com/ • SAS Cargo fulfills industry's need for fast and reliable transport solutions based on airfreight to, from, within and via Scandinavia. Sun-Airof ScandinaviaAJS www.sun-air.dk/ • SUN-AIRforbinder Jylland og ZUrich. F0rste flyvning fandt sted d. 28 april 2014. Se udsendte pressemeddelelse. Er din

**fl~•ming** aandret? SUN-AIR hjaalper dig
... Fly Scandinavian Airlines f.!fllll scandinavian-airlines.onetravel.comi

... 4.0

# ***** rating for onetravel.com Book Cheap Flights On Scandinavian Up To $15 Off Fees. Sa'le Big Now! One Travel has 585 followers on Google+ Scandinavian AirlinesAddress

**[;:7;1~** wow.com/Scandinavian+Airlines+Address

... Search for Scandinavian Airlines Address look Up Quick Results Now!



### Searches related to scandinaviaair scandinavia airlines scandinavia air pass sun air ofscandinavia primera air scandinavia primera air scandinavia als sas reservations www.scandanavian airlinesATTACHMENT DCERTIFICATE OF SERVICE I hereby certify that I have on this day served the forgoing Answer of Scandinavian Airlines System to the Application ofPrimera Air Scandinavia A/S by e-mail on the following persons: matwood@cozen.com rsilverberg@sgbdc.com marshall.sinick@sguiresanders.com Edward.sauer@squiresanders.com howard.kass@aa.com robert.wirick@aa.com Francis.heil@aa.com jcanny@amerijet.com rpommer@atlasair.com sascha.vanderbellen@delta.com nssparks@fedex.com cefelts@fedex.com jhill@cooley.com psanderlin@kalittaair.com Kevin.montgomery@polaraircargo.com agoerlich(a),ggh-airlaw.com jyoung(a),yklaw.com Thomas.

**ting(~suncotmtry**.com gmurphy@crowell.com dan.weiss@united.com steve.morrissey(a),united.com anita.mosner@hklaw.com jolm.s.duncan(a),faa.com

Date: August 5, 2014 

## /iT fre)Ti(;hnson