4770 Biscayne Blvd. Suite 830, Miami, FL 33137, USA Phone: 305 269 6975 Fax: 305 264 6575 Gerhard Rienecker President Michael Strauss CEO

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### U.S. Department of Transportation 1200 New Jersey Ave., S.E. Washington, D.C. 20590 USA Date: April 30 th 2013

To Whom It May Concern

The PASS Consulting Corporation (PASS), the Miami based branch of the PASS Consulting Group, hereby responds to the Application for Approval of an Agreement (Resolution 787, termed as New Distribution Capability or NDC) by the International Air Transport A ssociation (IATA) to the United States Department of Transportation (DOT) filed on March 11, 2013. We are delighted to inform you that we support the Resolution 787, as we see a substantial benefit of the NDC and consider it as very important for the

trave l industry.

PASS always had the idea of a unified standard in data structure and exchange for the travel industry. As long ago as 2000, PASS developed a XML standard, and since has sold the source code multiple times. The currently discussed NDC standard, originally suggested by the Open Axis Group, can be traced back
to PASS.

PASS supports IATA’s application and welcomes the movement towards a modern standard, which could in the long

- term replace working with the more antiquated EDIFACT. This electronic data interchange standard was first published in 1987, and therefore does not align a data transmission standard with the internet age. Even the first version of XML was already defined in 1998, so PASS

– and hopefully the rest of the travel industry

– is convinced it is time to finally enter a new era.

Technology should enable creative business models and not influence them. With the new standard there will be more competition amongst the airlines and distributors, which should lead to declining prices (d istribution constitutes a large part of the ticket price) and better customer service. With the no longer existing oligopoly (consisting of the three GDSs) and due to new search options, allowing travelers to personalize their flight not only by price but also by features (such as Wi

- Fi, entertainment, etc.) more competition will result from the NDC. Furthermore boycotts like seen with Sabre and4770 Biscayne Blvd. Suite 830, Miami, FL 33137, USA Phone: 305 269 6975 Fax: 305 264 6575 Gerhard Rienecker President Michael Strauss CEO

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- travel.c om/en Page 2 of 3 American Airlines would be more unlikely, which is very much appreciated. PASS moreover thinks the technology is good enough, if not already too antiquated again, to start this journey.

However PASS throws a critical look at Google, Apple and other technology companies: in the past years they all made clear, that they have the ideas and resources to run over the who le travel industry, by providing their own systems, which some of them have already patented. Compared to the past events in the music industry (discussing Napster and downloads, while Apple’s iTunes turned everything upside down), now the travel industry is at a point where other industries seem to be one step ahead.

The suggestion now would be to stop discussing whether XML, a now about 15 year old standard, should be implemented, but to look forward and give a special attention to the upcoming challenge s.
Regarding all concerns against the NDC, PASS would like to take a stand on the three main arguments of
this discussion:

1. The NDC will make the GDSs redundant. As seen today, it is already possible to sell tickets without collaboration with the GDSs: abo ut half of the tickets are directly sold by the airlines via the direct channel. Added to this, there are airlines (e. g. Easyjet), that sell their tickets exclusively over their website and not via the GDSs. As the DOT is not the advocate for the GDSs, it is not the task of the DOT to make sure the GDSs survive. In addition, PASS is convinced, that the GDSs are flexible and creative enough to improve their business case with newer technology (the NDC). Not least because they also operate successfully throu ghout the distribution chain: they run reservation

- , distribution

- and
sales

- systems.

2. Due to a lack of transparency caused by the NDC, there won ́t be any more comparability for customers, so that the prices will rise. PASS sees a gain of transparency, e nabled by the NDC. Today it appears that a traveler has more transparency when using a GDS, than using the direct channel. However, the transparency is only based on prices and not yet on features. In addition it is provided by only three GDSs, which
can i nfluence buying decisions. It seems to be unreasonable to give all this market power to only three profit

- oriented companies. A new standard could enable third

- party aggregators to provide transparency by company offers from airlines based on features in c ombination with prices. This causes advantages for the travelers: the needed transparency would increase, so that they can easily pick and choose and most important, compare the offers between different airlines. This would introduce middle ground from the two extremes: full transparency only on price, provided by GDSs, versus complicated comparison provided by direct distribution through suppliers websites.4770 Biscayne Blvd. Suite 830, Miami, FL 33137, USA Phone: 305 269 6975 Fax: 305 264 6575 Gerhard Rienecker President Michael Strauss CEO

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- travel.c om/en Page 3 of 3 3. The privacy of the traveler is compromised by the NDC. As entering personal information is and need s to stay optional, PASS cannot see any disadvantages for the travelers. Besides the GDSs are already working on the possibility to exchange frequent

- flyer information to make discounts accessible. With the Web 2.0 or Social Media, data privacy in the inte rnet age needs to be addressed in a global scale by governments and other institutions. It’s absurd to think that the travel industry can resolve these matters
alone.

All in all PASS feels confident that everything will stay in the way it is now and that the only change will be more transparency and the option for third

- party supplier to come up with innovative business models. People who want to be more flexible, will get the opportunity to search for personalized offers

– those who don’t can just skip th is option and search without entering personal information. This all will be made possible by a new and safer standard.

PASS therefore kindly requests that the DOT approves IATA Resolution 787.

We thank you for your kind consideration.

Sincerely,

Michael Strauss (CEO) PASS Consulting Corporation 4770 Biscayne Blvd., Suite 830 33137 Miami, FL http://www.pass

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