Benjamin Edelman

Complaint

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BEFORE THE DEPARTMENT OF TRANSPORTATION

OFFICE OF AVIATION ENFORCEMENT AND PROCEEDINGS

WASHINGTON, D.C.

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)

Benjamin Edelman, )

 third-party complainant )

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v. ) Docket DOT-OST-2013-____

)

Middle East Airlines ) 

)

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COMPLAINT OF BENJAMIN EDELMAN

Comments with respect to this document should be addressed to:

Benjamin Edelman

169 Walnut St.

Brookline, MA 02445

E-mail: ben@benedelman.org

Dated: December 16, 2013
Benjamin Edelman

Complaint

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BEFORE THE DEPARTMENT OF TRANSPORTATION

OFFICE OF AVIATION ENFORCEMENT AND PROCEEDINGS

WASHINGTON, D.C.

---------------------------------------------------------------)

)

Benjamin Edelman, )

 third-party complainant )

)

v. ) Docket DOT-OST-2013-____

)

Middle East Airlines ) 

)

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COMPLAINT OF BENJAMIN EDELMAN

1. This complaint arises out of Middle East Airlines mischaracterizing fees 

as “tax” and thereby failing to comply with applicable DOT requirements.

2. On December 14, 2013, I used the Middle East Airlines web site, 

mea.com.lb, to quote ordinary paid coach travel from New York JFK to Beirut, Lebanon. 

I found that the MEA site misrepresented carrier-imposed surcharge as “tax.”

3. Specifically, MEA provided the fare quote shown in Exhibit 1. MEA 

quoted a “flights” cost of $663 plus “taxes” of $734.84, for a total of $1397.84 EUR.

4. On information and belief, there is no “tax” of $734.84 on this route.

5. MEA’s statement of “tax” is literally false.

6. It is unfair and deceptive to characterize a charge as “tax” when it is set by 

a carrier of its own volition and need not be remitted to any government, airport, or 

similar authority. Such false statements provide consumers with inaccurate information 

as to the actual cost of their travel.
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7. I previously found that the MEA web site made the same false statement 

of “tax” on April 1, 2013. I retain appropriate screenshot proof which I can provide upon 

request. On information and belief, the false statements at issue occurred continuously 

throughout this period. I do not know when these false statements began.

8. I ask that the Department of Transportation:

(1) Exercise its authority under 49 USC 41712 to open an investigation of 

MEA for having engaged in, and continuing to engage in, the unfair 

and deceptive practices described above;

(2) Pursuant to such investigation, order MEA to refund to ticket 

purchasers all monies represented to ticket purchasers as “tax” or 

government-imposed fees, but not actually remitted to governments;

(3) Impose appropriate civil penalties on MEA; and 

(4) Refer this matter to appropriate US and foreign tax collection agencies 

for investigation of possible tax fraud or other violations of tax law in 

non-payment to governments of monies collected as “taxes” or 

government-imposed fees.

Pursuant to Title 18 United States Code Section 1001, I certify that I have not in 

any manner knowingly and willfully falsified, concealed or failed to disclose any material 

fact or made any false, fictitious, or fraudulent statement or knowingly used any 

documents which contain such statements in connection with the preparation, filing or 

prosecution of the pleading. I understand that an individual who is found to have violated 
Benjamin Edelman

Complaint

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the provisions of 18 U.S.C. section 1001 shall be fined or imprisoned not more than five 

years, or both.

Respectfully submitted,

/s/

Benjamin Edelman
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Complaint

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Attachment 1
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Certificate of Service

I hereby certify that I have, this 16th day of December, 2013 caused a copy of the 

foregoing Complaint to be served by electronic mail on the following persons:

Nour El Hashem elhachemn@mea.com.lb *

Samuel Podberesky, Esq. sam.podberesky@dot.gov

* - Because there was no MEA entry in the Regulations.gov docket for DOT-OST-2002-

12556 (Foreign - Designation of Agent for Service of Notice, Process, Orders, Decisions 

and Requirements), I obtained a contact name and email address from MEA’s web site. 

See http://www.mea.com.lb/English/Corporate/DirectoryHeadquarters/Pages/MEA.aspx , 

selecting Department: Legal Affairs. 

/s/

_____________________

Benjamin Edelman