ADELTA;% [::Pi cfj:]':^-omm 

I •• • 

Alexander Van der Bellen 

Managing Director and 

Associate General Counsel 

Delta Air Lines, Inc. 

1212 New York Avenue NW 

Washington, DC 20005 

202.842.4184 

sascha.vanderbellen@delta.com 

Februarys, 2010 

Ms. Dorothy Beard 

Chief, Docket Operations, M-30 

U.S. Department of Transportation 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: DeitaA^irgin Blue Group Antitrust Immunity Application 

Docket DOT-OST-2009-0155 

Dear Ms. Beard: 

Delta and the Virgin Blue parties request confidential treatment for the internal data submitted in 

response to Order 2009-11-20 (data question 2). The parties adopt and incorporate by 

reference their Rule 12 motion, filed on January 15, 2010, which covers this and all materials 

submitted in response to Order 2009-11-20. 

This data is being submitted in a sealed envelope marked "Confidential Treatment Requested 

under § 302.12." Access is restricted to counsel and outside experts who have filed valid 

confidentiality affidavits. Technical notes on the data are provided at Attachment A to this 

letter. 

Respectfully submitted. 

^^TAlexander Van der Bellen 

cc: Anita Mosner, esq. 

Sophy Chen, esq. 

Counsel to the Virgin Blue Parties 

Service List 
Attachment A 

Data Notes: 

• As agreed with Department staff. Delta's data production is limited to Delta/Northwest 

plated tickets and Virgin Blue's data production is limited to Virgin Blue Group plated 

tickets. 

• As requested by Department staff, in both data sets, instances of "NW were replaced 

with "DL" and instances of "DJ" were replaced with "VA" so Delta/Northwest is treated as 

a single carrier and V Australia/Virgin Blue is treated as a single carrier. 

• For Delta, market directional trips were broken based on the 24/4 rule requested in the 

Department's instructions. For Virgin Blue, 72 hours between departures was used as 

the principal basis for breaking the trip. Additional filters were used to accurately report 

shorter-duration O&Ds, however, there were instances where passengers returned on 

the next flight and origin is therefore reported as equaling destination in a very limited 

number of instances. 

• For Delta, ticket revenue was prorated based on the various proration methodologies 

used by Delta's Revenue Pipeline group in the ordinary course of business. Generally, 

proration methodologies vary based on whether other airlines are involved in the 

itinerary (in which case. Special Prorate Agreements or industry proration rules apply) 

or whether itineraries are wholly online (in which case Delta's internal proration rules ~ 

which use mileage as a factor ~ apply.) For Virgin Blue, proration is carried out by 

Virgin Blue's third party data services vendor using SPAs for all partner airlines. 

• For Delta, market fare amounts represent net revenue (i.e. they exclude taxes and 

fees). Taxes and fees are excluded because taxes and fees are not a part of 

the revenue realized by Delta and are therefore not recognized and prorated by Delta's 

revenue accounting systems in the same manner as fares. Fuel surcharges 

are included in Delta's market fare amounts and are prorated along with the base 

fare. For Virgin Blue, market fare amounts represent base fares plus fuel surcharges 

and exclude other taxes and fees. 

• For Delta, the Purchase Class field is comprised of the following 

categories: Unrestricted Business, Restricted Business, Unrestricted Economy, 

Restricted Economy, OA First, OA Business, OA Coach, and DL Emp Pass (Employee 

Pass Travel). As requested by the Department, the Purchase Class for the transpacific 

leg is listed as the Purchase Class for all segments of a market directional. The 

categorization of Unrestricted vs. Restricted only applies to journeys where Delta 

operated the transpacific leg. If an airline other than Delta operated the 

transpacific leg. Delta is only able to determine the passenger cabin, not the type of fare 

used. For Virgin Blue, the Purchase Class field is comprised of the following categories: 

Restricted Business, Restricted Economy, Restricted Premium Economy, Staff Business, 

Staff Economy, Staff Premium Economy, Unrestricted Business, Unrestricted Economy, 

and Unrestricted Premium Economy. The categorization of Unrestricted vs. Restricted 

only applies to journeys where V Australia operated the transpacific leg. V Australia has 

not identified the class or cabin if the leg is not operated by V Australia. 
CERTIFICATE OF SERVICE 

A copy of the foregoing Document has been served this S"' day of February, 2010, 

upon the following persons via email: 

Marshall S. Sinick 

Counsel for Alaska Airlines 

msinick@ssd.com 

Carl B. Nelson Jr. 

Associate General Counsel 

American Airlines Inc. 

carl.nelson@aa.com 

John L. Richardson 

Counsel for Amerijet International 

jrichardson@johnlrichardson.com 

Angeline Bird 

Sandra Lunsford 

Federal Express Corporation 

anbird@fedex.com 

sllunsford@fedex.com 

Mark Atwood 

Counsel for Kalitta Air 

matwood@sherblackwell.com 

Thomas V. Lydon 

Kelli Bryan 

Evergreen International Airlines, Inc. 

tom.lydon@evergreen.com 

charters@evergreenairlines.com 

Russell E. Pommer 

Associate General Counsel & Director of 

Regulatory Affairs 

Atlas Air, Inc. 

rpommer@atlasair.com 

Kevin P. Montgomery 

Polar Air Cargo, Inc. 

kevin.montgomery@polaraircargo.com 

Lawrence D. Wasko 

ldwasko@starpower.net 

Counsel for Arrow Air, Inc. 

Stephen Lachter 

lachter@starpower.net 

Counsel for ASTAR Air Cargo, Inc. 

Howard Kass 

Benjamin T. Slocum 

US Airways 

howard_kass@usairways.com 

benjamin.slocum@usairways.com 

David L. Vaughan 

Danielle Fisher 

Counsel for United Parcel Service 

dvaughan@kellydrye.com 

dfisher@kelleydrye.com 

Hershel Kamen 

Dan Weiss 

Continental Airlines 

hkamen@coair.com 

dan.weiss@coair.com 

Jeffrey A. Manley 

Julie Oettinger 

United Airlines 

jeffrey.manley@united.com 

julie.oettinger@united.com 

Mark McMillin 

Assistant General Counsel 

World Airways Inc. 

mcmillin@woa.com 

Malcolm Benge 

mlbenge@zsrlaw.com 

Counsel for World Airways Inc. 

Jonathan B. Hill 

jhill@dlalaw.com 

Counsel for Hawaiian Airlines, Inc 
John Byerly 

Deputy Assistant Secretary for Transportation Affairs 

U.S. Department of State 

byerlyjr@state.gov 

John Allen 

Federal Aviation Administration 

john.allen@faa.gov 

Todd Homan 

Peter Irvine 

U.S. Department of Transportation 

todd.homan@dot.gov 

peter.irvine@dot.gov 

Jill Ptacek 

U.S. Department of Justice 

Jill.Ptacek@usdoj.gov