BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

PRIMERA AIR SCANDINAVIA A/S 

for a foreign air carrier permit pursuant to 

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

pursuant to 49 U.S.C. § 40109 

(U.S. -EU Scheduled and Charter Air Transportation) 

) 

) 

) 

) Docket DOT-OST-2014-0125 

) 

) 

) 

) 

) 

____________________________________ ) 

ANSWER OF SCANDINAVIAN AIRLINES SYSTEM TO THE APPLICATION OF 

PRIMERA AIR SCANDINAVIA A/S FOR AN EXEMPTION AND FOREIGN AIR 

CARRIER PERMIT 

Communications with respect to this document should be addressed to: 

Hans Ollongren 

Head of Public and Regulatory Affairs 

SCANDINAVIAN AIRLINES 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 

PRIMERA AIR SCANDINAVIA A/S 

for a foreign air carrier permit pursuant to 

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

pursuant to 49 U.S.C. § 40109 

(U.S. -EU Scheduled and Charter Air Transportation) 

) 

) 

) 

) 

) 

) 

) 

) 

_____________________________________ ) 

Docket DOT-OST-2014-0125 

ANSWER OF SCANDINAVIAN AIRLINES SYSTEM TO THE APPLICATION OF 

PRIMERA AIR SCANDINAVIA A/S FOR AN EXEMPTION AND FOREIGN AIR 

CARRIER PERMIT 

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 of the requested exemption authority arid foreign air 

carrier permit 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 of these trade names, 

which are almost identical to that of Scandinavian 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 of Transportation ("Department") 

has long recognized its responsibility to safeguard the public from such confusion, and the 

Department has the power to take action if there is evidence of a significant potential for, or of 

actual, public confusion. 14 C.P.R. § 215.2. 
Answer of Scandinavian 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, Scandinavia Air or Primera Air Scandinavia.1 The application is silent on how 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 of the name represents the dedication of Scandinavian Airlines' employees to providing 

superior service as well as millions of dollars 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 of the 

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 of World War II; a copy of the 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]inor variations in the 

use of this name, including abbreviations, contractions, initial letters, or other variations of the name 

that are identifiable with the authorized name[.]" SAS maintains that the use by Primera of the 

names "Air Scandinavia" or "Scandinavia Air" would not constitute such a "minor variation" and 

therefore would be prohibited by Part 215 of the 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 of the Prim era application on the requirement that it will not use either of these 

names in holding out its U.S. services. 
Answer of Scandinavian Airlines System 

August 5, 2014 

Page 3 

advertises and markets the "Scandinavian Airlines" brand extensively in the US; examples of such 

advertisements and marketing efforts are provided in Attachment B hereto. 

Importantly, use of the "Air Scandinavia" or "Scandinavia Air" name by Primera 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 of any 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 

"Scandinavia Air." 

I. · The Department Has 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 or hold out to the public air transportation services in a name 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 of any 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 of operation or proposed area of operation, 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' of the intended name." 14 C.P.R. § 215.4(a). 
Answer of Scandinavian Airlines System 

August 5, 2014 

Page4 

where there is "evidence of a significant potential for, or of actual, public confusion." 14 C.P.R. § 

215.2. Of course, 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 of operations of the two carriers. Consideration of each of these factors 

demonstrates that Primera's use of the name "Air Scandinavia" or "Scandinavia Air" would cause 

consumer confusion. 

II. The Air Scandinavia and Scandinavia Air Names Will Cause Consumer Confusion 

A. Given the Similarity of the Air Scandinavia and Scandinavia Air Names to 

Scandinavian Airlines' Well-Established Brand Name, Consumer Confusion is 

Inevitable. 

There is no doubt that Primera's use of the 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 in the 

minds of the traveling public. This recognition has resulted from Scandinavian Airlines over 65 

3 See In the Matter of the Trade Name Issued to Hyannis Air Service, Inc. d/b/a Cape Air d/b/a 

Nantucket Airlines, 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 

on Review of StaffAction, 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 Air Pacific 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. Docket 40865, 98 C.A.B. 158 (Nov. 2, 1982), rev'd Order on Review of 

Staff Action (May 4, 1983) (denying application of Airpac, Inc. to use name Air Pacific Airlines, 

Inc. because of confusion with Air Pacific Limited). 
Answer of Scandinavian Airlines System 

August 5, 2014 

Page 5 

year history of operating 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 in the United States. SAS transported approximately 28 million passengers in 2013. 

SAS has invested heavily in the advertising and promotion of its "Scandinavian Airlines" 

brand across all types of media 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 below using the search terms "Air Scandinavia" demonstrate. 

Figure 1: Google Search Results for "Air Scandinavia" 

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Cht~.rp Scandk:allian Alr R~:!Hll\'<.!:i,m l.:1W F;;n Pr;;m:se. Bo:1!-: & S!!H N:>w! 

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Answer of Scandinavian 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 Scandinavian Airlines. But there 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 similar results for "Scandinavia Air." 

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 between New York/Newark, 

Washington, Chicago, Houston5 and San Francisco and Scandinavia, and codeshare flights on Star 

Alliance Partner United from a number of other 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 of similarity-named carriers overlap is an important 

consideration in the Department's consideration of whether consumer confusion is likely.6 Indeed, 

5 Effective August 20,2014. 6 Hyannis Order at 2 (revoking name registration because "both air carriers intend to operate in the 

same geographic region"). 
Answer of Scandinavian Airlines 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 of consumer 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 Scandinavian Airlines' existing operations, including: 

Foreign scheduled and charter air transportation of persons, property and 

mail from any point or points behind any Member State of the European 

Union, via any point or points in any Member State and via intermediate 

points, to any point or points in the 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 

much more than a "significant potential" for geographic overlap. The grant of Primera' s application 

will result in actual overlapping operations that will inevitably result in consumer confusion were it 

to use either the "Air Scandinavia" or "Scandinavia Air" 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 of SAS and Primera 

aircraft livery), SAS has no way to know whether Primera plans to use different livery for its U.S.-

EU transatlantic services. What is clear is that both companies will operate their U.S. services with 

7 Airpac Order at 2. 

8 Appl. ofPrimera Air Scandinavia A/S For A Foreign Air Carrier Permit and Exemption Authority 

at 3 (July 21, 2014). 9 Airpac Order at 2. 
Answer of Scandinavian Airlines 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 "Scandinavia Air" livery on its U.S. flights. 

III. To Avoid Consumer Confusion, the Department Must Condition Primera's Exemption 

and Foreign Air Carrier Permit Applications 

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 or unfair methods of competition. Moreover, the Department should exercise its authority 

to intervene when a proposed name has a significant probability of causing 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 of the decision. Despite the apparent disparate operations, 

the CAB concluded that confusion between "Air Pacific" and "Air Pacific 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 "Air Pacific" was identified with the services provided by 

the Fiji carrier by consumers after years of marketing efforts. 11 Consequently, the CAB denied the 

application of the Alaskan carrier to change its name. Far beyond what the Fiji carrier had done in 

the Airpac case, SAS has spent an incredible amount of money 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 

intended to use that authority and would likely advertise in areas where Airpac operated. 11 Airpac Order at 2. 
Answer of Scandinavian 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-opt those names and devalue the investments SAS has made to the detriment of the 

traveling public who are likely to believe the companies are affiliated and as a result make illinformed purchase decisions. If the 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 condition the grant of any 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. 

in the name "Air Scandinavia" or "Scandinavia Air." 

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 of Scandinavian 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 "Scandinavia Air," and for such other or further relief as it deems appropriate and consistent with 

the public interest. 

Dated: August 5, 2014 

Respectfully submitted, 

~£~-u.A 

L. 

Michael 

Jeffrey 

F. 

Johnson 

Goldman ~ 

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 A 
Entity Information Page 1 of2 

NYS Department of State 

Division of Corporations 

Entity Information 

The information contained in this database is current through July 29,2014. 

Selected Entity Name: SCANDINAVIAN AIRLINES OF NORTH AMERICA INC. 

Selected Entity Status Information 

Current Entity Name: SCANDINAVIAN AIRLINES OF NORTH AMERICA INC. 

DOS ID #: 59792 

Initial DOS Filing Date: SEPTEMBER 16, 1946 

County: NEW YORK 

Jurisdiction: NEW YORK 

Entity Type: DOMESTIC BUSINESS CORPORATION 

Current Entity Status: ACTIVE 

Selected Entity Address Information 

DOS Process (Address to which DOS will mail process if accepted on behalf of the entity) 

NATIONAL CORPORATE RESEARCH, LTD. 

10 E. 40TH STREET 

10TH FLOOR 

NEW YORK, NEW YORK, 10016 

Chief Executive Officer 

MR. STEFAN LARSSON 

C/0 SAS 

9 POLITO A VENUE 

LYNDHURST, NEW JERSEY, 07071 

Principal Executive Office 

SCANDINAVIAN AIRLINES OF NORTH AMERICA INC. 

C/0 SAS 

9 POLITO A VENUE 

LYNDHURST, NEW JERSEY, 07071 

Registered Agent 

NATIONAL CORPORATE RESEARCH, LTD. 

10 E. 40TH STREET 

10TH FLOOR 

NEW YORK, NEW YORK, 10016_ • 
Entity Information 

This office does not record information regarding 

the names and addresses of officers, shareholders 

or directors of nonprofessional corporations except 

the chief executive officer, if provided, which 

would be listed above. Professional corporations 

must include the name(s) and address(es) ofthe 

initial officers, directors, and shareholders in the 

initial certificate of incorporation, however this 

information is not recorded and only available by 

viewing the ce1iificate. 

*Stock Information 

# of Shares Type of Stock $ Value per Share 

0 Capital Stock 175000 

*Stock information is applicable to domestic business corporations. 

Name History 

Entity Name 

Page 2 of2 

Filing Date Name Type 

APR 25, 1980 Actual 

SEP 16, 1946 Actual 

SCANDINAVIAN AIRLINES OF NORTH AMERICA INC. 

SCANDINAVIAN AIRLINES SYSTEM, INC. 

A Fictitious name must be used when the Actual name of a foreign entity is unavailable for use in 

New York State. The entity must use the fictitious name when conducting its activities or business in 

New York State. 

NOTE: New York State does not issue organizational identification numbers. 

Services/Programs 

• 

Search Results New Search 

Privacy Policy I Accessibilitv Policy I Disclaimer I Return to DOS 

Homepage I Contact Us 
ATTACHMENT B 

• 

II 

Our Late Flight NewarkCopenhagen is back. 

Always with SAS 

SK902 departs Monday, Wednesday and Thursday at 11 :30pm 

Business, Economy Extra, Economy 

60 destinations in Scandinavia: 

EuroBonus points 

Scandinavian Airlines 

flysas.com/us A STAR ALLIANCE MEMBER v~.,:"' 
SAS Plus Benefits: 

Separate cabin 1 More legroom 1 More seat recline 

Wider seatw/leg rest I Upgraded meals I Video on demand 

2 checked bags 1 2 carry-on bags 

Priority boarding I Priority baggage 

SAS lounge access 

flysas.com/us 

*Upgrade is Free for infants. Subject to availability of meals. EB points according to original ticketed booking class. Not available for award tickets. 

1111 

Scandinavian Airlines 

A STAR ALLIANCE MEMBER v~-

ATTACHMENT C 
AAA) If search term is Air Scandinavia: 

Anytime 

Past hour 

Past 24 hours 

Past week 

Past month 

Past year 

All results 

Verbatim 

Web Images Videos News Shopping Maps Books 

About 8.820.000 results 

Scandinavian Airlines -Fly with Scandinavia's leading Airline 

~~~~ w~WJ.flysas.comi ... 

Book your flight here! 

SA.S has 4.071 followers on Google+ 

Fly to Copenhagen (CPH) 

Fly to Stockholm (ARN) 

Fly to Oslo (OSL) 

Fly to Gothenburg 

Flv Scandinavian Airlines- OneTravel.com 

~~] scandinavian-airlines.onetravel.com/ • 

4.0 *****rating fur onetravel com 

Book Cheap Flights On Scandinavian Up To $15 Off Fees. Save Big Now! 

One Travel has 535 followers on Google+ 

SAS: Flights to Sweden, Norway and Denmark- Scandinavian Airlines 

www.flysas.com/enlusi ,.. 

Welcome to the official SAS US website. 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 __ _ 

Sun Air of 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 a franchise __ _ 

Scandinavian Airlines - Wikipedia, the free encvdopedia 

en. wikipedia.orglwikilScandinavian _Airlines ,.. 

Scandinavian Airlines or SAS, previously Scandinavian Airlines System, is the flag ... 

Source: ICAO Digest of Statistics for 1950-55, lATA World Air Transport ... 
Scandinavian Airlines- Star Alliance 

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 in gar 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 Air All 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 to air scandinavia 

air scandinavian 

swiss air 

sun air of scandinavia baggage allowance 

primera air scandinavia a/s 

BBB) If search term is Scandinavia Air 

sas reservations 
Any 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 

Scandinavian Airlines - Fly with Scandinavia's leading Airline 

&~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) 

Scandinavian Airlines - Double Up - orbitz.com 

t~li www.orbitz.com/Scandinavian-Airlines • 

Earn On Top Of Miles With the Orbitz Rewards VISA Card 

Scandinavian Airlines - Find Cheap Flight Tickets & Save 

[\;;J{~ W\'YI.'V.cheaptickets.com/ "' 

Book Now With Cheaptickets® 

-

SAS: Flights to Sweden, Norway and Denmark- Scandinavian Airlines 

\'1/VilW.flysas.comten/usJ • 

SAS offers you low fares to and from Scandinavia and to the whole world .. 

SAS 

SAS offers cheap flights to 

Scandinavia, Europe, Asia and ... 

Online check-in 

See if your flight is eligible for online 

check-in. •Also applies ... 

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en.wikipedia.orgfwiki/Scandinavian _Airlines ,.. 

Scandinavian Airlines or SAS, previously Scandinavian Airlines System, is the flag __ _ 

Source: ICAO Digest of Statistics for 1950-55, lATA World Air Transport __ _ 

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Sun-Air of Scandinavia AJS 

www.sun-air.dk/ • 

SUN-AIR forbinder Jylland og ZUrich. F0rste flyvning fandt sted d. 28 april 2014. Se udsendte 

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ATTACHMENT D 


CERTIFICATE OF SERVICE 

I hereby certify that I have on this day served the forgoing Answer of Scandinavian 

Airlines System to the Application of Primera 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 

F rancis.heil@aa. com 

jcanny@amerij et. 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