BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C.

___________________________ 

) 

In The Matter of ) 

) Docket No. OST-2013- 0048 

) 

Agreement Adopted by the ) 

Passenger Services Conference ) 

Of the International Air ) 

Transport Association as ) 

Resolution 787 ) 

__________________________ ) 

REPLY OF OPEN ALLIES FOR AIRFARE TRANSPARECNY TO IATA’S 

PRELIMINARY RESPONSE TO MOTION 

David Kelly 

Executive Director 

Open Allies for Airfare Transparency 

 439 New Jersey Ave., SE 

 Washington, DC 20003 

 (703) 786-0980 

 david@stormkingstrategies.com 

March 27, 2013 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C.

___________________________ 

) 

In The Matter of ) 

) Docket No. OST-2013- 0048 

) 

Agreement Adopted by the ) 

Passenger Services Conference ) 

Of the International Air ) 

Transport Association as ) 

Resolution 787 ) 

__________________________ ) 

REPLY OF OPEN ALLIES FOR AIRFARE TRANSPARECNY TO IATA’S 

PRELIMINARY RESPONSE TO MOTION 

Open Allies for Airfare Transparency (“Open Allies”) hereby replies to the March 26, 

2013 “Preliminary Response” of Applicant International Air Transport Association to the March 

18, 2013 Motion of Open Allies To Require Applicant to Produce Additional Documents or, in 

the Alternative, Extend the Comment Period.1 While Open Allies appreciates IATA’s 

willingness to extend the comment period to April 25, 2013, its contention “that document 

requests are properly considered as substantive comments on IATA’s Application” makes no 

sense on its face. Open Allies asked in its Motion that IATA be required to produce documents 

that will help explain IATA’s purpose and intentions in seeking approval for Resolution 787 and 

resolve some of the inconsistencies between IATA’s Application and other statements that IATA 

has made concerning that Resolution and the New Distribution Capability that the Resolution 

promotes so that commenters will have access to the relevant facts as they prepare their answers. 

Such documents are needed so that the Department can benefit from more informed comments 

and a fuller picture of the Application. Open Allies did not file its Motion with the intent that it 

 

1 Open Allies asks that this short Reply be accepted in order to remove any doubt as to its position in light 

of IATA’s Response. 
2 

be considered its comments on the Application, but to receive the documents it needs to fully 

develop such comments. Nor does an extension of time, while welcome, address the need for 

IATA to produce relevant documents. 

The idea that parties should file comments first and only later have an opportunity to see 

requested documents is plainly backwards. However, should the Department decide that 

documents will not need to be produced until after comments have been filed, then Open Allies 

urges the Department to allow for a second round of comments to be filed after the documents 

are made available. 

Respectively submitted, 

/s/ David Kelly 

David Kelly 

Executive Director 

Open Allies for Airfare Transparency 

 439 New Jersey Ave., SE 

 Washington, DC 20003 

 (703) 786-0980 

 david @stormkingstrategies.com 

March 27, 2013 
CERTIFICATE OF SERVICE 

I certify that a copy of the Reply of Open Allies for Airfare Transparency was served on 

the 27th day of March by first class or priority mail on the following persons: 

Douglas Lavin 

Regional Vice President – North America 

International Air Transport Association 

1201 F Street, NW, Suite 650 

Washington, DC 20004 

Bert W. Rein 

Bruce L. McDonald 

Wiley Rein LLP 

1776 K Street, NW 

Washington, DC 20006 

 

Chief, Transportation, Energy & 

Agriculture Section 

Antitrust Division 

Department of Justice 

Washington, DC 20530 

David Radcliff 

Chief Executive Officer 

Hogg Robinson Group 

16 E. 34th Street, 3rd Floor 

New York, NY 10016 

 

Paul Ruden 

Senior Vice President of Legal and 

Industry Affairs 

American Society of Travel Agents 

1101 King Street, Suite 200 

Alexandria, VA 22314 

Pat Funk 

Executive Director 

Association of Retail Travel Agents 

4320 North Miller Road 

Scottsdale, AZ 85251-3606 

 

Eric Bock 

Executive Vice President, Chief Legal 

Officer and Chief Administrative Officer 

Travelport 

300 Galleria Parkway 

Atlanta, GA 30339 

Grey Webb 

President 

Sabre Travel Network 

3150 Sabre Drive 

Southlake, TX 76092 

 

Scott Gutz 

President and Chief Executive Officer 

Amadeus North America, Inc. 

3470 NW 82nd Avenue, Suite 1000 

Miami, FL 33122 

Barney Harford 

Chief Executive Officer 

Orbitz Worldwide Inc. 

500 W. Madison St., Suite 1000 

Chicago, IL 50551 

 

Dara Khorsrowshahi 

President/CEO 

Expedia, Inc. 

333 108th Avenue, NE 

Bellevue, WA 98004 

Robert L. Darbelnet 

CEO/President 

AAA Travel (AAA Inc.) 

1000 AAA Drive 

Heathrow, FL 32746 

 

 
2 

Douglas Anderson 

President/CEO 

Carlson Wagonlit Travel 

701 Carlson Parkway 

Minneapolis, MN 55305 

Sam Jain 

CEO/Chairman 

Travelong Inc. 

212 W. 35th St., Suite 1302 

New York, NY 10001 

 

Jeffery H. Boyd 

President/CEO 

Priceline.com 

800 Connecticut Avenue 

Norwalk, CT 06854 

Michael Batt 

Chairman/Founder 

Travel Leaders Group 

3033 Campus Drive, Suite W320 

 

Joop Drechsel 

Chief Executive Officer 

BCD Travel 

6 Concourse Parkway, Suite 2400 

Atlanta, GA 30328 

Norman Knowles 

Group VP 

Loyalty Travel Agency 

6442 City West Parkway 

Eden Prairie, MN 55344 

 

Dean Smith 

President 

FC USA 

69 Spring St. 

Ramsey, NJ 07446 

Bryan Leibman 

President/CEO 

FROSCH 

1 Greenway Plaza, Suite 800 

Houston, TX 77046 

 

William H. Tech 

CEO/President 

Travel and Transport Inc. 

2120 S. 72nd Street 

Omaha, NE 68124 

Priscilla Alexander 

President 

Protravel International Inc. 

515 Madison Avenue 

New York, NY 10022 

 

Alexandre Chemla 

President 

Altour International Inc. 

1270 Avenue of the Americas, 15th FLOOR 

New York, NY 10020 

Brad Tolkin/Jeff Tolkin 

Co-Chairman/CEO 

World Travel Holdings 

100 Fordham Road 

Wilmington, MA 01887 

 

Peter Liney 

Chief Executive Officer 

STA Travel 

750 State Highway 121, Suite 250 

Louisville, TX 75067 

James E. Wells 

Chief Executive Officer 

World Travel Inc. 

1724 West Schuylkill Road 

Douglassville, PA 19518 

 

 
3 

Gloria Rohan 

CEO/President 

Omega World Travel 

3100 Omega Office Park 

Fairfax, VA 22031 

Tammy Krings 

CEO/Leadership Coach 

TS24 

7775 Walton Parkway 

New Albany, OH 4304 

 

Paul Metselaar 

Chairman/CEO 

Ovation ravel Group 

71 Fifth Avenue 

New York, NY 10003 

Yoshimori Himeno 

President 

JTB 

19700 Mariner Avenue 

Torrance, CA 90503 

 

Jeff Smith 

President 

Travizon Inc. 

275 Mishawum Road, Suite 300 

Woburn, MA 01801 

Lisa Durocher 

SVP/General Manager 

American Express 

World Financial Center 

200 Vesey Street 

New York, NY 10285 

 

Patrick Fragale 

President/COO 

Directravel 

860 Wyckoff Avenue 

Mahwah, NJ 07430 

Jonathan Perkel 

Senior VP, General Counsel 

Travelocity 

3150 Sabre Drive 

Southlake, TX 76092 

 

Dr. Elijah Chingosho 

Secretary General 

African Airlines Association 

2nd Floor AFRAA Building, Red Cross 

Road 

South C, Off Mombasa Road, Nairobi 

P.O. Box 20116, Nairobi, Kenya 

Hans Ollongren 

Senior Vice President 

Scandinavian Airlines Systems 

19587 

Stockholm-Arlanda 

Kabinvagen 5 

 

Andrea Fischer Newman 

Sr. Vice President, Government Affairs 

Alexander Van der Bellen 

Managing Director, Government Affairs 

and Associate General Counsel 

Christopher Walker 

Regional Director, Government Affairs 

Delta Airlines, Inc. 

1212 New York Avenue, N.W. 

Washington, DC 20005 

Chris Phillips 

Managing Director – Distribution Strategy 

Delta Air Lines, Inc. 

1030 Delta Boulevard 

Atlanta, GA 30320 

 
4 

Maribeth L. Minella 

Sr. Vice President & Corporate Counsel 

World Travel, Inc. 

620 Pennsylvania Drive 

Exton, Pennsylvania 19341 

Arnold Cheng 

General Manager International Affairs 

Cathay Pacific 

9/F, Central Tower 

Cathay Pacific City, 8 Scenic Road 

Hong Kong International Airport 

Lantau, Hong Kong 

 

Mohamed Bhanji 

VIA Rail Canada 

3 Place Ville Marie 

Montreal, Canada 

H3B 2C9 

Michael J. Premo 

President & CEO 

Airlines Reporting Corporation 

3000 Wilson Boulevard 

Suite 300 

Arlington, V 22201-3862 

 _/s/ David Kelly_____________________ 

 David Kelly