BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

American Airlines

Multiple Price Advertising Violations of

49 U.S.C. § 41712 and 14 CFR 399.84(a)

Docket DOT-OST-2013-0024

COMMENTS IN SUPPORT OF DOT INVESTIGATION INTO AMERICAN AIRLINES 

INC VIOLATIONS AND ADDITIONAL FACTS

Communications with respect to this document should be sent to:

Mike Borsetti

1 Montgomery St Ste 2500

San Francisco, CA 94104

mike@borsetti.com

21 March 2013
1

BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

American Airlines

Multiple Price Advertising Violations of

49 U.S.C. § 41712 and 14 CFR 399.84(a)

Docket DOT-OST-2013-0024

COMMENTS IN SUPPORT OF DOT INVESTIGATION INTO AMERICAN AIRLINES 

INC VIOLATIONS AND ADDITIONAL FACTS

I strongly encourage the Secretary to exercise its authority under 49 U.S.C. § 41712 to 

investigate and impose sanctions on American Airlines for the unfair and deceptive practices 

described in Mr. Edelman’s complaint, Document DOT-OST-2013-0024-0001, and in doing so 

fulfill its mission.

In addition, I would like to provide the following additional information to the Secretary 

in aiding its decision making.

AMERICAN AIRLINES TELEPHONE REPRESENTATIVE MISREPRESENTATION

On 31 January at approximately 6:30PM PT I called American Airlines to change ticketed 

award travel involving carriage on British Airways. The representative misstated the price of the 

new itinerary to me as “taxes”, when in reality the vast majority of it was in fuel surcharges.
2

AMERICAN AIRLINES E-TICKET CONFIRMATIONS ARE INCOMPLETE AND DO NOT SEPARATE 

CARRIER-IMPOSED FEES

The emailed e-ticket I received as a result of the abovementioned change did not break 

apart taxes from carrier-imposed fees: all was lumped-in under “Additional Fare Collection”.

American Airlines, unlike most other airlines, no longer provides customers with the 

information that has been historically provided to all travelers in the ticket, specifically fare 

calculation, individual tax breakdown, and restrictions/endorsements.

I urge the DOT to require American Airlines (and all airlines should such requirement not 

be in existence) to continue to provide such complete disclosure to their customers with their eticket confirmation/receipt so that passengers know exactly what they have purchased. The 

current disclosure “boilerplate”1is so vague to be irrelevant without further details such as the 

restriction line of the ticket.

 

1

The disclosure as it appears in the email, at 100% its original size:
3

RELEVANT COMMENTS IN A DIFFERENT DOCKET

I would like to alert the Secretary that some of the comments filed in Docket DOT-OST2013-0025 contain evidence of misrepresentation by American Airlines, and should therefore be 

considered in this Docket. These comments include, to date, those of Ann Shooshani in DOTOST-2013-0025-0029 and Deirdre Elizabeth Seim in DOT-OST-2013-0025-0041, but this list is 

probably incomplete.

RESOLUTION

In view of the preponderant evidence and ample public support, the Secretary should 

open an investigation on American Airlines under 49 U.S.C. § 41712 without further ordering

the required resolution from the complaint.

I further urge the DOT to require American Airlines (and all airlines should such 

requirement not be in existence) to provide complete ticket details in their email 

confirmation/receipt.

Furthermore, the complaint provides evidence that American Airlines was first made 

aware of the violations on 31 December 2011, over 15 months ago, and is continuing to engage 

in the unfair and deceptive manners described. I strongly urge the Secretary to take into account 

each day from that date as a separate violation when imposing a civil penalty as per 49 USC § 

46301.

Submitted via regulations.gov on 21 March 2013

/s/
4

Mike Borsetti