EDGEWORTH ECONOMICS’

EMPIRICAL INVESTIGATION AND ANALYSIS OF ECONOMIC ISSUES RAISED IN

“RESTORING OPEN SKIES: THE NEED TO ADDRESS SUBSIDIZED COMPETITION FROM STATEOWNED AIRLINES IN QATAR AND THE U.A.E.”

MAY 21, 2015
TABLE OF CONTENTS

I. EXECUTIVE SUMMARY ......................................................................................................... 1

II. EXPERTS’ QUALIFICATIONS.................................................................................................. 3

A. John H. Johnson, IV.......................................................................................................................3

B. Michael Kheyfets...........................................................................................................................3

III. ASSIGNMENT........................................................................................................................ 4

IV. ASSESSMENT OF CLAIMS REGARDING “VALUE” OF THE OPEN SKIES AGREEMENTS ............ 4

V. ASSESSMENT OF CLAIMS REGARDING “GULF CARRIERS TAKING SHARE WITHOUT 

MEANINGFULLY STIMULATING DEMAND” .......................................................................... 6

VI. ASSESSMENT OF ALLEGATIONS REGARDING DISPLACEMENT OF U.S. CARRIERS............... 13

VII. ASSESSMENT OF HISTORICAL PUBLISHED FARE TRENDS ON KEY ROUTES ........................ 16

A. Analysis of Published Fares on Key Routes Between the United States and the Indian 

Subcontinent ................................................................................................................................17

B. Benchmarking Etihad’s U.S.-ISC Published Fares to Those of Carriers on Other 

International Routes.....................................................................................................................20

VIII. ASSESSMENT OF U.S. CARRIERS’ INTERNATIONAL TRAFFIC PATTERNS............................. 22

IX. ASSESSMENT OF ALLEGATION THAT CAPACITY GROWTH EXCEEDS GLOBAL GDP

GROWTH .......................................................................................................................... 26

X. ASSESSMENT OF ANALYSES IN THE COMPASS LEXECON REPORT....................................... 30

A. The Compass Lexecon Report Fails to Establish a Causal Link Between the Analyses it 

Presents and the Alleged Subsidies..............................................................................................31

B. The Compass Lexecon Report Focuses Only On U.S.-International Passenger Traffic, 

Ignoring Key Evidence ................................................................................................................33

C. The Entirety of Analyses in the Compass Lexecon Report are Predicated on a False Notion 

That Etihad and Other Gulf Carriers Must “Stimulate Demand” in Order to be Allowed to 

Operate.........................................................................................................................................35

D. The “Basic Analysis” in the Compass Lexecon Report Has Substantial Problems.....................36

E. The Regression Analyses in the Compass Lexecon Report Have Substantial Problems.............37
I. EXECUTIVE SUMMARY

1. The analyses in this report represent an investigation of specific assertions made in a report 

entitled “Restoring Open Skies: The Need to Address Subsidized Competition From State-Owned Airlines 

in Qatar and the UAE,” (“Open Skies Report”)1 as well as economic issues closely related to those 

assertions.

2

 Our findings are as follows:

• The assertion that Etihad Airways (“Etihad”) disproportionally benefits from the bilateral Open Skies

agreement because there are more Etihad flights than those offered by U.S. carriers between Abu 

Dhabi and the U.S. represents an incorrect characterization and analysis of competition in the airline 

industry. 

- The appropriate level of analysis when examining competitive alternatives for passenger air travel 

is between origin and destination (“OD”) combinations and not between a carrier’s hub (i.e., Abu 

Dhabi) and a destination. For example, a passenger who wants to travel from New York City to 

Mumbai can travel on Etihad with a connection in Abu Dhabi or—for example—on American 

Airlines/British Airways with a connection in London. Though these two journeys do not 

connect in the same location, they do in fact compete for the same customers.

• The assertion that Etihad “takes passengers” from U.S. carriers ignores the fact that the overall 

volume of travel on these routes has expanded since Etihad began operating on them, and that Etihad 

serves routes either not served or potentially underserved by U.S. carriers. It also ignores the 

competition among (i) Gulf carriers, (ii) U.S. carriers, and (iii) other carriers.

- Between 2009 and 2014, the total volume of passenger traffic between the U.S. and key regions 

served by Etihad (such as the Indian Subcontinent (“ISC”) and the Middle East) increased, in 

some cases substantially.

- In some instances, the U.S. carriers’ losses in share of passengers were more than offset by the 

increase in their total number of passengers traveling on a certain route. For example, while 

members of Immunized Alliances3 served a smaller share of total U.S. to ISC traffic in 2014 than 

1 Restoring Open Skies: The Need to Address Subsidized Competition From State-Owned Airlines in Qatar and the 

UAE, January 28, 2015. (“Restoring Open Skies”)

2 The analyses presented below rely on data that Etihad has provided from third party and proprietary sources. We 

have had discussions with Etihad business personnel regarding these data.

3 For the purposes of this report, “Immunized Alliances” are defined in accordance with the U.S. Department of 

Transportation Compendium of Antitrust Immunity Cases. See U.S. DOT Compendium of Antitrust Immunity 

Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014). This includes Delta, Air France-KLM, Alitalia, Czech, 

Korean, Virgin Atlantic, United, Air Canada, Brussels, Lufthansa, Swiss, Austrian, SAS, LOT, TAP United, Air 

1

 
they did in 2009 (36 vs. 41 percent), they actually served 18 percent (over 223,000) more 

passengers in 2014 because of the growth in the overall volume of travel on this route.

• Pricing in the airline industry is complex and it is important that appropriate comparison groups be 

developed when analyzing prices of multiple carriers on the same OD pair. Based on our analysis, 

Etihad’s published economy class fares on routes between the U.S. and the ISC are close to or slightly 

lower than the median fares published by competing carriers. However, the magnitudes of 

differences vary across routes, with Etihad being above the typical fares published for some routes.

- A analysis benchmarking Etihad’s median revenue per kilometer (“RPK”) on routes between the

U.S. and ISC to fares published by Immunized Carriers on transatlantic routes—where 

coordination between U.S. and foreign carriers is allowed by way of antitrust immunity conferred 

by the U.S. government—indicates that Immunized Carriers’ RPK is substantially higher.

• The assertion that Etihad (together with other Gulf carriers) is adding capacity at a rate greater than 

forecasted growth in demand is inconsistent with economic intuition and is predicated on faulty 

analysis. When the analysis is revised to account for a more appropriate proxy for growth in demand, 

the implied growth in demand for air travel services is actually greater than the estimated capacity 

expansion.

- An analysis of U.S. Department of Transportation data indicates that while Etihad has increased 

the number of available seats on flights between the U.S. and its hub in Abu Dhabi, its load 

factors have remained around 80 percent.

2. This report also includes an initial assessment of claims made in a report entitled “Assessing the 

Impact of Subsidized Gulf Carrier Expansion on U.S.-International Passenger Traffic,” (“Compass 

Lexecon Report”)4 as well as of the analyses on which those claims are based. Our initial findings are 

that the conclusions reached in the Compass Lexecon Report are based on analyses that (i) have not been 

shown to have any causal link to the alleged subsidies, (ii) rely solely on U.S.-international passenger 

traffic and ignore other relevant evidence, and (iii) are predicated on the notion that in order to compete, 

new entrants must “stimulate demand” by serving only customers not already served by an incumbent

U.S. carrier. These conclusions are further based on regression models that are fundamentally flawed.

New Zealand, Asiana United, All Nippon Airways, COPA, American Airlines, Lan Airlines, Lan Peru, British 

Airways, Iberia, Finnair, Royal Jordanian, Japan Air Lines, Virgin Australia.

4 Darin Lee, Ph.D. and Eric Amel, Ph.D., Assessing the Impact of Subsidized Gulf Carrier Expansion on U.S.-

International Passenger Traffic, May 13, 2015. (“Compass Lexecon Report”)

2

 
II. EXPERTS’ QUALIFICATIONS

A. John H. Johnson, IV

3. I am the President and CEO of Edgeworth Economics, L.L.C. (“Edgeworth”). Edgeworth is a 

consulting firm that provides clients with objective expert economic and financial analysis for 

complex litigation and public policy debates. Edgeworth’s experts work in a wide range of applied 

economics and econometrics fields, including antitrust and class certification. Edgeworth has offices in 

Washington, D.C., San Francisco, CA, and Pasadena, CA. I am also on the Board of Directors of both 

National Appleseed—a nonprofit network of 17 public interest justice centers in the United States and 

Mexico—and the Hawaii Appleseed Center for Law and Economic Justice.

4. I received my B.A. magna cum laude with highest distinction in Economics from the University 

of Rochester and my Ph.D. in Economics from the Massachusetts Institute of Technology (“MIT”). My 

areas of specialization at MIT were econometrics—the application of statistics to economics—and labor 

economics. During my career as a professional economist, I have provided economic analysis in a wide 

range of litigation matters involving class certification, antitrust, labor and employment, damages 

calculation, and statistics. Prior to my employment as an economic consultant, I was an Assistant 

Professor of Economics and Labor and Industrial Relations at the University of Illinois at UrbanaChampaign, where I taught courses in labor economics. I have also taught as an Affiliated Professor at 

Georgetown University’s Public Policy Institute, including a course on Antitrust and Public Policy.

5. I have testified and provided consulting on a wide-range of antitrust matters related to class 

certification, liability, and damages. I also have written numerous papers and given many talks on topics 

related to class certification, scientific standards in litigation, appropriate use of econometrics in litigation, 

and antitrust damages. I previously was an Editor of the Antitrust Law Journal. I submitted an amicus 

brief to the United States Supreme Court in Comcast vs. Behrend on the role of economic analysis in 

assessing the appropriateness of antitrust class certification. I have been accepted as an expert in 

Economics, Econometrics, and Statistics in Federal District Courts.

B. Michael Kheyfets

6. I am a Partner at Edgeworth and a professional economist who provides economic and financial 

research and analysis for clients in a variety of matters. I received my B.A. degree with magna cum laude

and Phi Beta Kappa honors, as well as an M.A. degree in economics from Boston University. As a 

consulting economist, I have advised a variety of clients in litigation, advisory, and regulatory contexts. I 

have developed and analyzed large datasets for complex litigation matters and have employed statistical 

modeling to calculate damages for antitrust and labor disputes. I have also provided expert advice for 

3
clients on a range of financial modeling issues outside of litigation, including in the areas of energy, 

telecommunications, and commercial real estate. I am also a member of the American Bar Association’s 

Section of Antitrust Law Economics Committee. In this role, I develop resources to educate members of 

the legal community about issues in economics and statistics.

III.ASSIGNMENT

7. We have been asked by Etihad to review the “Restoring Open Skies” Report,

5 which we 

understand was published by a group called Partnership for Open & Fair Skies on January 28, 2015. We 

have also been asked to assess several economic claims made by the authors of this report—which 

include, among others, American Airlines, Delta Air Lines, and United Airlines6

—as well as to develop 

empirical analyses to evaluate these claims. Lastly, we have been asked to conduct an analysis of 

historical published fare trends on key Etihad routes.

8. Additionally, we have been asked to provide our preliminary views on a report published on May 

13, 2015 by economists Darin Lee, Ph.D. and Eric Amel, Ph.D. of the consulting firm Compass Lexecon, 

and to assess several economic claims made in that report.

7

IV.ASSESSMENT OF CLAIMS REGARDING “VALUE” OF THE OPEN SKIES AGREEMENTS

9. The Open Skies Report argues that “the Open Skies agreements have conferred enormous 

benefits on Qatar and the UAE by opening the most lucrative market in the world to their airlines, even 

though they provide essentially no benefit to U.S. carriers in return.”8

 This is, the authors of the Open 

Skies Report claim, because of the “low level of demand for travel originating in the two Gulf 

countries.”9

10. The notion that Etihad disproportionally benefits from the bilateral agreement because Etihad

offers more flights between Abu Dhabi and the U.S. than U.S. carriers do represents an incorrect analysis 

of competition in the airline industry. The appropriate level of analysis when examining competitive 

5 See http://www.openandfairskies.com/wp-content/themes/custom/media/White.Paper.pdf, Accessed May 20, 2015.

6 See http://www.openandfairskies.com/about-us/, Accessed May 20, 2015.

7 See http://www.openandfairskies.com/wp-content/uploads/2015/05/CL-paper-on-Gulf-Carrier-Traffic-1.pdf, 

Accessed May 20, 2015.

8 Restoring Open Skies, p. 3.

9 Ibid.

4

 
alternatives for passenger air travel is between origin and destination combinations10 and not between a

particular carrier’s hub (i.e., Abu Dhabi) and a destination.

11. Exhibit 1 illustrates this issue. For example, a passenger who wants to travel from New York 

City to Mumbai has many options. That passenger can travel on Etihad with a connection in Abu Dhabi 

or on a number of other carriers, including:

11

• American Airlines/British Airways with a connection in London;

• Emirates with a connection in Dubai;

• United/Lufthansa/Swiss Air with a connection in Frankfurt, Munich, or Zurich;

• Air India with a connection in Delhi;

• Turkish Airlines with a connection in Istanbul;

• Qatar Airways with a connection in Doha; or

• Delta/Air France/KLM with a connection in Paris or Amsterdam.

Though none of these journeys connect through the same hub, they do in fact compete for the same 

customers, as the customers are seeking to travel from one city to the other. It is not, however, relevant 

for an analysis of competition on this route where the trip connects before proceeding to the final 

destination (e.g., connecting in Abu Dhabi vs. Istanbul).

10 See e.g., Brueckner, Jan, Darin Lee, and Ethan Singer. “City-Pairs Versus Airport-Pairs: A Market-Definition 

Methodology for the Airline Industry.” Review of Industrial Organization 44.1 (2014): 1-25. European Commission 

and the United States Department of Transportation, Transatlantic Airline Alliances: Competitive Issues and 

Regulatory Approaches, November 16, 2010. (Available at 

http://ec.europa.eu/competition/sectors/transport/reports/joint_alliance_report.pdf, Accessed May 20, 2015)

11 http://www.rome2rio.com/s/New-York-JFK/Mumbai-Airport-BOM-India, Accessed May 20, 2015.

5

 
EXHIBIT 1

ILLUSTRATION OF APPROPRIATE ANALYSIS OF COMPETITIVE ALTERNATIVES

ON THE JFK-BOM ROUTE

Source: http://www.rome2rio.com/s/New-York-JFK/Mumbai-Airport-BOM-India, Accessed May 20, 2015.

V. ASSESSMENT OF CLAIMS REGARDING “GULF CARRIERS TAKING SHARE WITHOUT 

MEANINGFULLY STIMULATING DEMAND”

12. The Open Skies Report presents various statistics to purportedly demonstrate that Etihad and the 

other Gulf-based carriers are not “meaningfully stimulating demand.”12 For example, it contends that 

“the average daily bookings between the United States and the three Gulf hubs has increased by only 85 

passengers per day” from 2008 to 2014.13 As an initial matter, this calculation is simply wrong. For 

example, in the 12 months between March 2009 and February 2010, there were an average of 174 daily 

bookings between the U.S. and Abu Dhabi. In the 12 months between March 2014 and February 2015,14

there were an average of 574 daily bookings between these destinations. This amounts to an increase of 

12 Restoring Open Skies, p. 48.

13 Id, p. 49. (Emphasis in original)

14 Etihad provided us with proprietary third party bookings data through February 2015. As a result—in order to use 

the latest available data—we define the years in our analyses between March and February. Additionally, our 

analyses indicate that overall demand for air travel declined between 2008 and 2009 as a result of the economic 

downturn generally referred to as the “Great Recession.” Therefore, in order to distinguish the effects of the 

recession from those of the changing competitive landscape in the airline industry, we begin our analyses of travel 

volumes in 2009.

6

 
400 bookings—or approximately 230 percent—per day.

15 What this entire analysis ignores, however, is 

that by offering passengers access to destinations beyond their hubs, Etihad and the other Gulf-based 

carriers have served a growing overall demand for travel to and from the United States, particularly on 

routes that were either unserved or potentially underserved by U.S. carriers and their European partners.

16

13. For example, a substantial portion of Etihad’s U.S.-based traffic originates (or terminates) on the 

ISC. In order to study whether Etihad’s presence on this segment of travel has served growing demand 

(or responded to “pent-up demand”), we have conducted an analysis of passenger flow on Etihad’s OD 

pairs—individually and in aggregate—that connect the U.S. and ISC. Specifically, we analyzed data 

from Marketing Information Data Transfer (“MIDT”) databases17 to assess the total number of 

passengers traveling between the U.S. and destinations in the ISC. We calculated total traffic between (i) 

the U.S. and key regions served by Etihad, (ii) the U.S. and key countries served by Etihad, and (iii) key 

OD pairs connecting Etihad’s U.S. gateway locations to the ISC.

18 Exhibit 2 provides an illustration of 

how the overall volume of economy class travel between U.S. and ISC has grown since 2009. Similar 

analyses for additional key routes are attached as Appendix A.

15 Average daily bookings between the United States and Dubai in these two periods increased from 1,204 to 2,076, 

an increase of over 870 bookings—or over 70 percent—per day.

16 Notably, even today, U.S. carriers do not offer direct service to many of the regions Etihad serves. Rather, they 

partner with carriers from Germany, France, and United Kingdom—among others—to service these routes. (See 

e.g., ¶11, supra.) Moreover, the U.S. carriers also use the networks of the three Gulf carriers to transport their 

passengers to these destinations. For example, Qatar Airways is a member of the Oneworld Alliance, in which 

American Airlines is the U.S. partner. American Airlines also has a codeshare agreement with Etihad to serve many 

of the regions it does not fly to itself. 

17 The MIDT system captures passenger bookings, irrespective of whether the passenger actually traveled. We use 

the marketing carrier for a particular booking for the purposes of our analysis.

18 Our analysis of specific OD pairs focuses on the top two routes by total passenger flow between Etihad’s U.S.

gateway cities and six destinations in the ISC. These routes include New York to Delhi, San Francisco to Delhi, 

New York to Mumbai, San Francisco to Mumbai, New York to Islamabad, Washington, DC to Islamabad, New 

York to Dhaka, Washington, D.C. to Dhaka, New York to Colombo, Los Angeles to Colombo, Chicago to 

Hyderabad, and New York to Hyderabad.

7

 
EXHIBIT 2

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND INDIAN SUB-CONTINENT

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes:

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases. See footnote 3, above.

2 Traffic flows are non-directional.

3 Indian Sub-Continent includes Bangladesh, India, Pakistan, and Sri Lanka. 

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).

14. As this exhibit shows, the total volume of annual travel between the U.S. and ISC increased by 

approximately one million passengers—or 33 percent—between 2009 and 2014. Etihad served close to 

300,000 more passengers in 2014 than it did in 2009, which represents 10 percent growth relative to total 

volume of travel in 2009. Similarly, the Immunized Alliances, which include United, Delta, and 

American Airlines—as well as their European partners19—served approximately 224,000 more 

passengers in 2014 than they did in 2009, or 7 percent growth relative to total volume of travel in 2009.

15. Exhibit 3 provides a summary of our analysis, which shows the portion of the overall economy 

class growth on these routes served by each carrier.

19 See footnote 3, above, for the full list of carriers that have antitrust-immune relationships with the U.S. carriers.

8

 
EXHIBIT 3

SERVED SHARE OF OVERALL GROWTH IN VOLUME OF TRAVEL

BETWEEN UNITED STATES AND KEY REGIONS

ECONOMY CLASS

2009 – 2014

Notes: 

1 This analysis compares total travel volume between March 2014 and February 2015 to the total travel volume 

between March 2009 and February 2010.

2 Indian Sub-Continent includes Bangladesh, India, Pakistan, and Sri Lanka. Other carriers include, among 

others, Air India, Cathay Pacific, Jet Airways, Turkish Airlines, Kuwait Airways, Pakistan International Airlines, 

Singapore Airlines, Air China, China Southern Airlines, and Saudi Airlines.

Middle East includes Bahrain, Iran, Iraq, Jordan, Kuwait, Lebanon, Oman, Qatar, Saudi Arabia, Syrian Arab 

Republic, Yemen, and United Arab Emirates. 

Other carriers include, among others, Saudi Arabian Airlines, Turkish Airlines, Gulf Air, Kuwait Airways, 

EgyptAir, Aeroflot, Jet Airways, and Cathay Pacific.

3 Traffic flows are non-directional. Numbers may not add up due to rounding.

4 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases. See footnote 3, above.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).

10% 9%

18%

10%

1%

42%

20%

33%

47%

20%

10%

55%

7%

-1%

-5%

7%

18%

0%

-5%

12%

4%

-5% -6%

-9%

-15%

-5%

5%

15%

25%

35%

45%

55%

65%

75%

Indian Sub-Continent Middle East Bangladesh India Pakistan Sri Lanka

Etihad Airways Emirates & Qatar Airways Immunized Alliances Other

Total Change in 

Bookings

+33%

Total Change in 

Bookings

+54%

Total Change in 

Bookings

+64%

Total Change in 

Bookings

+32%

Total Change in 

Bookings

+22%

Total Change in 

Bookings

+88%

9
16. Exhibit 4 provides a summary which shows the portion of the overall premium class growth on 

these routes served by each carrier.

EXHIBIT 4

SERVED SHARE OF OVERALL GROWTH IN VOLUME OF TRAVEL 

BETWEEN UNITED STATES AND KEY REGIONS

PREMIUM CLASS

2009 – 2014

Notes: 

1 This analysis compares total travel volume between March 2014 and February 2015 to the total travel volume 

between March 2009 and February 2010.

2 Indian Sub-Continent includes Bangladesh, India, Pakistan, and Sri Lanka. Other carriers include, among 

others, Air India, Cathay Pacific, Jet Airways, Turkish Airlines, Kuwait Airways, Pakistan International Airlines, 

Singapore Airlines, Air China, China Southern Airlines, and Saudi Airlines.

Middle East includes Bahrain, Iran, Iraq, Jordan, Kuwait, Lebanon, Oman, Qatar, Saudi Arabia, Syrian Arab 

Republic, Yemen, and United Arab Emirates. 

Other carriers include, among others, Saudi Arabian Airlines, Turkish Airlines, Gulf Air, Kuwait Airways, 

EgyptAir, Aeroflot, Jet Airways, and Cathay Pacific.

3 Traffic flows are non-directional. Numbers may not add up due to rounding.

4 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases. See footnote 3, above.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).

11%

19%

12% 12%

-5%

61%

36%

51%

102%

36%

13%

100%

15%

6%

-23%

15%

20%

-1%

4%

15%

29%

5%

-14%

21%

-35%

-15%

5%

25%

45%

65%

85%

105%

125%

Indian Sub-Continent Middle East Bangladesh India Pakistan Sri Lanka

Etihad Airways Emirates & Qatar Airways Immunized Alliances Other

Total Change in 

Bookings

+65%

Total Change in 

Bookings

+91%

Total Change in 

Bookings

+119%

Total Change in 

Bookings

+69%

Total Change in 

Bookings

+13%

Total Change in 

Bookings

+181%

10
17. Some notable findings from these analyses are:

20

• Economy cabin travel between the U.S. and ISC increased by 33 percent from 2009 to 

2014. Premium cabin travel increased by 65 percent over the same period.

• Economy cabin travel between the U.S. and the Middle East increased by 54 percent from 2009 to 

2014. Premium cabin travel increased by 91 percent over the same period.

• Members of the Immunized Alliances served 7 percent of the growth in U.S. to ISC traffic relative to

total volume of travel in 2009, driven primarily by increases in traffic served to India and Pakistan.

• Gulf carriers have served a substantial portion of the growth in volume of traffic between the U.S. and 

Sri Lanka—e.g., Etihad alone served 42 percent of the increase in the overall economy class traffic 

volume on this route relative to 2009. However, members of the Immunized Alliances have offered 

little or no service on these routes.

18. Exhibit 5 summarizes the growth of the overall volume of economy and premium class travel on 

key routes between the U.S. and ISC.

20 It is our understanding that much of Etihad’s premium class traffic between U.S. and Pakistan is derived from 

U.S. government passengers. The corresponding drops in Etihad traffic and rises in the Immunized Carrier traffic 

are due to new U.S. carrier marketed fares on that route, as we understand that the U.S. government requires its 

personnel to use U.S. marketed fares if they are available.

11

 
EXHIBIT 5

GROWTH OF THE OVERALL VOLUME OF TRAVEL

ON KEY ROUTES BETWEEN UNITED STATES AND INDIAN SUB-CONTINENT

BY CABIN CLASS

2009 – 2014

Notes: 

1 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

2 Traffic flows are non-directional.

Source: MIDT.

19. Notably, some of the largest growth has been on routes in which there is little or no participation 

from members of Immunized Alliances. For example, between 2009 and 2014, (i) economy traffic on the 

New York to Colombo route grew by 127 percent, while premium traffic grew by 205 percent; (ii) 

economy traffic on the Los Angeles to Colombo route grew by 70 percent, while premium traffic grew by 

187 percent; and (iii) economy traffic on the New York to Dhaka route grew by 74 percent, while 

premium traffic grew by 134 percent. Taken together, these analyses indicate that the claim made in the 

Open Skies Report that Etihad and other Gulf-based carriers “can continue to grow only by capturing 

37%

70%

127%

31%

74%

27%

9%

21%

31%

8%

115%

54%

96%

187%

205%

62%

134%

81%

-10%

46%

113%

76% 78%

-41%

-75%

-25%

25%

75%

125%

175%

225%

Percent Change in Overall Volume of Travel

Economy Premium

12
market share from other airlines” is unsupported by the facts.21 Rather, these carriers also can grow and 

have been growing by serving the expanding overall volume of traffic between the U.S. and other 

countries.

VI.ASSESSMENT OF ALLEGATIONS REGARDING DISPLACEMENT OF U.S. CARRIERS

20. In order to evaluate the claim that Gulf carriers “take passengers”22 from U.S. carriers, we

analyzed travel flow data from the MIDT system to assess each carrier’s share of passengers traveling

between the U.S. and destinations in the ISC. However, looking solely at changes in shares of total travel 

obscures the fact that in some instances, the U.S. carriers’ losses in share of passengers were offset by 

the increase in their total number of passengers traveling on a certain route. That is, because of growing 

demand on a particular route, U.S. carriers may benefit from higher numbers of passengers, even if other 

carriers have a relatively larger share of the total traffic.23

21. Exhibit 6 simultaneously illustrates the change between 2009 and 2014 in the Immunized 

Alliances’ total volume of economy class traffic serviced between U.S. and key regions, as well as the 

change during that period in the Immunized Alliances’ share of economy class traffic serviced. In this 

exhibit, circles centered above the horizontal axis represent routes where the Immunized Alliances gained 

traffic volume between 2009 and 2014; circles centered to the left of the vertical axis represent routes 

where the Immunized Alliances lost share of traffic volume between 2009 and 2014. 

22. For example, a circle representing travel between U.S. and ISC is located in the upper-left 

quadrant of Exhibit 6, indicating that while the Immunized Alliance Members lost 4.4 percentage points 

of the overall volume of economy class traffic on this route between 2009 and 2014 (reducing their share 

from 40.7 to 36.3 percent), they actually serviced 18 percent (or over 223,000) more passengers.

23. Similar analyses for additional key routes between the U.S. and ISC, as well as a summary of the 

analyses, is attached as Appendix B.

21 Restoring Open Skies, p. 11.

22 Restoring Open Skies, p. 2.

23 This claim also fails to take into account external factors that may be responsible for certain carriers choosing to 

limit or terminate service on certain routes in the region, such as armed conflicts or other security concerns. The 

assessment of these factors, none of which were addressed in the Open Skies Report, are beyond the scope of our 

analysis.

13

 
EXHIBIT 6

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN UNITED STATES AND KEY REGIONS

ECONOMY CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases. See footnote 3, above.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Indian Sub-Continent includes Bangladesh, India, Pakistan, Sri Lanka, and Nepal. 

Middle East includes Bahrain, Iran, Iraq, Jordan, Kuwait, Lebanon, Oman, Qatar, Saudi Arabia, Syrian Arab 

Republic, Yemen, and United Arab Emirates. 

4 Traffic flows are non-directional. The value on the chart represents the differences in traffic volumes between 

2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).

24. Exhibit 7 illustrates a similar analysis of premium class traffic, showing the change between 

2009 and 2014 in the Immunized Alliances’ total volume of traffic between U.S. and key regions, as well 

as the change during that period in the Immunized Alliances’ share of premium class traffic.

Indian Sub-Continent

+223,737

India

+176,629

Middle East

-14,324

Bangladesh

-6,093

Sri Lanka

-38

Pakistan

+53,240

-100%

-50%

0%

50%

100%

150%

200%

-40% -30% -20% -10% 0% 10% 20%

Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings

14
EXHIBIT 7

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN UNITED STATES AND KEY REGIONS

PREMIUM CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases. See footnote 3, above.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Indian Sub-Continent includes Bangladesh, India, Pakistan, Sri Lanka, and Nepal. 

Middle East includes Bahrain, Iran, Iraq, Jordan, Kuwait, Lebanon, Oman, Qatar, Saudi Arabia, Syrian Arab 

Republic, Yemen, and United Arab Emirates. 

4 Traffic flows are non-directional. The value on the chart represents the differences in traffic volumes between 

2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).

25. Some notable findings from these analyses are that while the Immunized Alliances:

Indian Sub-Continent

33,805

India

30,051

Middle East

13,825

Bangladesh

-1,084

Sri Lanka

-33

Pakistan

+4,871

-120%

-100%

-80%

-60%

-40%

-20%

0%

20%

40%

60%

80%

100%

-40% -30% -20% -10% 0% 10% 20% 30%

Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings

15
• lost 4.4 percentage points of the overall volume of economy class traffic on the U.S.-ISC route 

between 2009 and 2014 (reducing their share from 40.7 to 36.3 percent), they actually serviced 18 

percent (or over 223,000) more passengers.

• lost 12.5 percentage points of the overall volume of premium class traffic on the U.S.-ISC route 

between 2009 and 2014 (reducing their share from 54.3 to 41.8 percent), they actually serviced 27

percent (or over 33,000) more passengers.

• lost 23.8 percentage points of the overall volume of premium class traffic on the U.S.-Middle East 

route between 2009 and 2014 (reducing their share from 56.5 to 32.7 percent), they actually serviced

10 percent (or over 13,000) more passengers.

VII. ASSESSMENT OF HISTORICAL PUBLISHED FARE TRENDS ON KEY ROUTES

26. Pricing in the airline industry is highly complex, both because of the (i) varied arrangements that 

exist among American and European carriers that allow them to jointly operate international flights on 

certain North Atlantic routes with immunity from applicable antitrust laws, and (ii) carriers’ individual 

strategic decisions about on which routes to offer service and the manner in which to offer such service 

(i.e., “online,” codeshare, or bilateral commercial agreement).24 For example, our understanding is that in 

instances in which two carriers have a codeshare or bilateral commercial agreement, the fare for the entire 

trip (either non-stop or with connections) is likely to be more competitive relative to the fares charged 

separately by carriers for the individual segments of the trip. In contrast, some carriers may simply 

publish fares without issuing rules that limit the eligible airlines or routings (this is called a non-restricted 

industry type fare). In these instances, the publishing carrier does not have a codeshare or bilateral 

commercial agreement with the connecting carrier, and therefore simply “adds on” the connecting 

carrier’s segment fare, resulting in a less competitive total fare.

27. Our analysis is limited to those fares on which (i) one carrier serves the entire route (i.e., the 

“online” carriers), (ii) the carriers that serve the route are party to a codeshare agreement, or (iii) the 

carriers that serve the route are party to a bilateral commercial agreement.25 In order to identify the 

relevant carriers on each route, we have relied on an analysis of bookings data and discussions with 

Etihad’s personnel. Including non-restricted industry type fares (i.e., instances where carriers “add on” 

24 A Special Prorate Agreement (“SPA”) is an example of a bilateral commercial agreement. 

25 Our understanding, based on discussions with Etihad’s pricing personnel, is that by publishing non-restricted 

industry type fares for routes on which they do not have a codeshare or interline agreements, carriers affirmatively 

chose not to offer a fare that is competitive with those published by carriers that do have commercial agreements. 

As a result, these non-commercial fares are not included for the purposes of our analysis. 

16

 
the connecting carrier’s segment fare) that do not meaningfully compete with those types of traffic would 

provide an overly broad range of fares.26

A. Analysis of Published Fares on Key Routes Between the United States and the Indian 

Subcontinent

28. We have developed a series of analyses which compare Etihad’s published fares between its U.S. 

gateway cities and key destinations in the ISC to fares published by other carriers on these routes. For 

each of the key routes,27 we have compared Etihad’s median published economy cabin fares to the 

median published economy cabin fares of each carrier that operates on that route in one of the three ways 

described above (distinguishing between fares offered by members of Immunized Alliances from those 

offered by other carriers).

28

29. Exhibit 8 presents an illustration of this analysis for published fares on the route between New 

York and Delhi. As this exhibit shows, Etihad’s published fares are at the high end of the range for some 

parts of the period, and at the low end for others. For example, in the two years since April 2013, 

Etihad’s fare on this route has been on average (i) $47 (or 3 percent) lower than the route median fare

published by the U.S. and foreign Immunized Alliance members; and (ii) $194 (or 11 percent) higher than 

the route median fare published by non-immunized carriers. 

Similar analyses for each of the 12 key U.S.-ISC routes are attached as Appendix C.

26 It is our understanding that the authors of the Open Skies Report have not alleged the existence of predatory 

pricing by Etihad and other Gulf-based carriers, and we have not performed a predatory pricing analysis to 

determine whether Etihad priced its services below its average variable costs. (Our understanding is that predatory 

pricing in the airline industry has previously been at issue in United States of America v. AMR Corporation, 

American Airlines, Inc., and AMR Eagle Holding Company. See http://www.justice.gov/atr/cases/f8100/8134.htm, 

Accessed May 20, 2015)

27 The 12 key routes include JFK-DEL, SFO-DEL, JFK-BOM, SFO-BOM, JFK-ISB, IAD-ISB, JFK-DAC, IADDAC, JFK-CMB, LAX-CMB, ORD-HYD, and JFK-HYD.

28 We have used bookings volume data from MIDT to identify and exclude from the analysis instances where 

carriers publish fares on routes they do not generally operate. Additionally, for the purposes of consistency, 

published Premium Economy fares are not included in our analysis.

17

 
EXHIBIT 8

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON NEW YORK CITY TO DELHI ROUTE

APRIL 2013 – MARCH 2015

Notes:

1 Immunized Alliance members included in this analysis are American, Delta, United, British Airways, KLM, and 

Lufthansa. Etihad's fare was on average $47 (or 3%) lower than the median offered by these carriers.

2 Non-Immunized carriers included in this analysis are Emirates, Qatar Airways, Air India, and Turkish Airways. 

Etihad's fare was on average $194 (or 11%) higher than the median offered by these carriers.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to U.S. dollars. 

Premium Economy fares are not included in the analysis.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.

30. Exhibit 9 presents a summary of our pricing analyses across the 12 key U.S.-ISC routes. 

18
EXHIBIT 9

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES

ON FLIGHTS BETWEEN KEY UNITED STATES AND INDIAN SUB-CONTINENT DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases. See footnote 3, above.

2 Non-Immunized carriers included in this analysis are Emirates, Qatar Airways, Air India, and Turkish Airways.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to U.S. dollars. 

Premium Economy fares are not included in the analysis.

4 Immunized Alliance Members did not offer flights on the New York to Dhaka and Los Angeles to Colombo 

routes during this period.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.

31. Some notable findings from these analyses are:

• Immunized Alliance carriers do not offer flights from New York to Dhaka or from Los Angeles to 

Colombo. On these routes, Etihad’s published fares are higher than the medians of the fares 

published by non-immunized carriers.

• Etihad began operating out of SFO in November 2014. In the five months since then, its published 

fares to Mumbai and Delhi have been the lowest relative to non-immunized carriers on the 12 key 

routes, which is not unusual for a new route under development.

29

29 We understand this to be the case based on discussions with Etihad.

Average of Etihad's Average of Etihad's

Average of Price Difference Average of Price Difference

Monthly Fares from Median Competitor Monthly Fares from Median Competitor

Route On Route3 Percent Dollars On Route3 Percent Dollars

[a] [b] [c] [d] [e] [f] [g]

New York to Delhi $2,011 -3% -$47 $1,770 11% $194

San Francisco to Delhi $1,778 -5% -$82 $1,857 -9% -$161

New York to Mumbai $2,031 -7% -$136 $1,707 11% $189

San Francisco to Mumbai $1,841 -8% -$154 $1,873 -10% -$186

New York to Hyderabad $1,891 5% $99 $1,850 7% $140

Chicago to Hyderabad $2,013 -1% -$17 $2,028 -2% -$31

New York to Islamabad $2,024 -7% -$139 $1,833 3% $52

Washington to Islamabad $2,101 -19% -$393 $1,755 -3% -$47

New York to Dhaka -- -- -- $1,787 5% $100

Washington to Dhaka $2,680 -26% -$704 $1,817 9% $159

New York to Colombo $2,156 -11% -$228 $1,924 0% $4

Los Angeles to Colombo -- -- -- $1,540 13% $197

Immunized Alliance Members1 Non-Immunized Carriers2

19

 
• Etihad’s published fares on the New York to Hyderabad route have been higher than the median 

published by other carriers, including members of Immunized Alliances. Its published fares from 

Chicago to Hyderabad have been essentially the same as both immunized and non-immunized 

carriers.

B. Benchmarking Etihad’s U.S.-ISC Published Fares to Those of Carriers on Other 

International Routes

32. We have also been asked by Etihad to develop an analysis comparing Etihad’s published fares on 

routes between the U.S. and ISC, which rely on comparing Etihad’s U.S. to ISC revenue per kilometer 

(“RPK”) to RPK on routes where Etihad does not offer service. While—as noted above—pricing in the 

airline industry is highly complex, we developed this benchmarking analysis to conduct an initial 

assessment of how pricing may differ between routes where Etihad operates and ones that are not affected 

by the allegations against Etihad and other Gulf carriers.

33. The benchmarking group includes transatlantic routes operated by the Immunized Alliances 

(including United, Delta, American, British Airways, Lufthansa, and Air France-KLM). For each of the 

12 key U.S.-ISC routes, we calculated Etihad’s median published economy class RPK in each month and 

compared that series to the median published per-kilometer economy fares of the immunized carriers on 

transatlantic routes that originated in the same U.S. gateway.

34. For example, Exhibit 10 shows a comparison of per-kilometer published fares on Etihad’s flights 

from New York to Delhi and those on transatlantic routes originating from New York operated by 

members of antitrust-immunized alliances. Similar analyses for each of the 12 key U.S.-ISC routes are 

attached as Appendix D.

20
EXHIBIT 10

ETIHAD REVENUE PER KILOMETER ON NEW YORK TO DELHI ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUE PER KILOMETER

FROM NEW YORK TO FRANKFURT, LONDON, AND PARIS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to U.S. dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: Air France, American, British Airways, Delta, KLM, Lufthansa, and United.

Benchmark includes fares published by carriers on the following routes: NYC-FRA, NYC-LON, NYC-PAR.

3 There are 7 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 70% higher than Etihad's median fare.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.

21
Notably, Immunized Alliance Members’ RPK on transatlantic routes where coordination between U.S. 

and foreign carriers is allowed by way of antitrust immunity conferred by the U.S. government were 69 to 

120 percent higher than Etihad’s median RPKs on routes between the U.S. and ISC.

VIII. ASSESSMENT OF U.S. CARRIERS’ INTERNATIONAL TRAFFIC PATTERNS

35. Our analysis of pricing on transatlantic routes in the previous section—together with the fact that 

price coordination between the respective U.S. and foreign carriers is allowed by way of antitrust 

immunity conferred by the relevant antitrust and competition regulators—suggests that the shorter 

transatlantic flights may be generally more valuable for the Immunized Alliance members than other 

(longer) routes in their networks. As a result, because U.S. carriers and their European partners have the 

option of allocating their resources between these routes and others, it is instructive to consider how U.S. 

carriers allocate their capacity across the networks they serve.

36. By entering into partnerships with flagship European carriers that are immunized from antitrust 

laws, American Airlines, Delta Air Lines, and United Airlines have structured their businesses in such a 

way that a substantial portion of their international traffic passes through Europe; specifically, through the 

hub airports of their respective European partners. The result of this arrangement—in which each U.S. 

carrier directs substantial traffic through their single respective European hub—is that a single 

transatlantic flight may have passengers who eventually travel to a broad range of final destinations. For 

example, on an United flight from the U.S. to Frankfurt:

• a portion of the passengers will terminate their trip in Frankfurt;

30

• some may continue to other European destinations; and

• others still may continue on to Africa, Asia, or the ISC. 

This means that there is a scarcity of passenger capacity, and carriers must decide which mix of 

passengers will most profitably fill a particular transatlantic flight. As a result, U.S. passengers looking to 

travel to the ISC may find a dearth of options available from the U.S. carriers if those carriers can fill their 

planes with passengers who seek to travel only to the European hub, or continue to a destination other 

than the ISC.

37. Our analysis of U.S. Department of Transportation data indicates that over the last several years,

U.S. carriers’ load factors (a measure of capacity utilization) on travel between the U.S. and their 

30 Similarly, (i) some passengers on a particular Delta flight from the U.S. may only be interested in the direct travel 

to Paris, while others may be connecting to a destination beyond the Air France hub, and (ii) some passengers on a 

single American Airlines flight from the U.S. may only be interested in the direct travel to London, while others 

may be connecting to a destination beyond the British Airways hub.

22

 
antitrust-immunized partners’ hubs have been generally stable. For example, as Exhibit 11 shows, since 

2007, the combined load factors of Delta, American, and United on these routes remained at 

approximately 80 percent. This means that there has been high demand for U.S. carriers’ transatlantic 

services relative to the capacity those carriers have allocated to that segment. 

EXHIBIT 11

AGGREGATE LOAD FACTORS FOR DELTA, AMERICAN, AND UNITED AIRLINES

BETWEEN THE UNITED STATES AND AMSTERDAM, FRANKFURT, LONDON, AND PARIS

NOVEMBER 2006 – OCTOBER 2014

Source: U.S. DOT Bureau of Transportation Statistics, Air Carrier Statistics: T-100 International Segments.

38. Given the high load factors, it stands to reason that a revenue-optimizing U.S. carrier would set 

its fares for travel to the ISC in such a way that the marginal ISC-bound passenger would only displace a 

valuable Europe-bound passenger on a transatlantic route if the fare for the U.S.-ISC trip is sufficiently 

high. As Exhibit 12 shows, approximately 70 percent of the U.S. carriers’ economy and premium class 

traffic originating in the U.S. and passing through the hub cities of their European partners terminates 

after the flight to the hub city. Similarly, approximately 20 percent of U.S. carriers’ economy and 

premium class traffic originating in the U.S. and passing through the hub cities of their European partners 

80% 79% 79%

82%

79% 80% 81%

79%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Nov2006 -

Oct2007

Nov2007 -

Oct2008

Nov2008 -

Oct2009

Nov2009 -

Oct2010

Nov2010 -

Oct2011

Nov2011 -

Oct2012

Nov2012 -

Oct2013

Nov2013 -

Oct2014

Load Factor

23
continues to destinations elsewhere in Europe. In fact, of the total traffic U.S. carriers have sent through 

the hub cities of their immunized European partners in the most recent 12 months, only 2 percent of each 

economy and premium class has been ultimately destined for the ISC.

EXHIBIT 12

DELTA, AMERICAN, AND UNITED AIRLINES’ CONNECTING VS. POINT-TO-POINT TRAFFIC

ON FLIGHTS FROM THE UNITED STATES TO/THROUGH KEY EUROPEAN CITIES

MARCH 2014 – FEBRUARY 2015

Notes: 

1 Key European Cities include London, Paris, Frankfurt, and Amsterdam.

2 Indian Sub-Continent includes Bangladesh, Bhutan, India, Maldives, Nepal, Sri Lanka, and Pakistan.

Sources:

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).

39. The allocation of U.S. carriers’ capacity shown in Exhibit 12 is consistent with the discussion 

above. That is, for U.S. carriers, traffic to the hub cities of their respective European partners is most 

valuable on an RPK basis, because of their antitrust-immune arrangements, as well as because those trips 

are both direct and shorter. The connections to other regions (including the ISC) are relatively less

2%

73%

19%

6%

Premium Class

Indian Sub-Continent Point-to-Point Europe Other International

2%

69%

21%

8%

Economy Class

24
valuable. As a result, because of the value of direct and intra-Europe flights, there is little “displacement” 

of those passengers by those wanting to go from U.S. to the ISC.

40. Etihad’s network is different. While hundreds of thousands of passengers fly every year between 

the U.S. and its hub in Abu Dhabi, Etihad’s passenger flow generally continues beyond its domestic hub, 

primarily to the ISC. As Exhibit 13 shows, while 14 percent of Etihad’s economy class traffic between 

March 2014 and February 2015—the latest 12 months for which data are currently available—terminated 

in Abu Dhabi, 66 percent proceeded beyond its hub to the ISC. Similarly, while 50 percent of Etihad’s 

premium class traffic during this period terminated in Abu Dhabi, an additional 32 percent proceeded 

beyond to the ISC.

EXHIBIT 13

ETIHAD’S CONNECTING VS. POINT-TO-POINT TRAFFIC

ON FLIGHTS FROM THE UNITED STATES TO/THROUGH ABU DHABI

MARCH 2014 – FEBRUARY 2015

Note: Indian Sub-Continent includes Bangladesh, India, Maldives, Nepal, Sri Lanka, and Pakistan.

Source: MIDT.

14%

66%

20%

Economy Class

50%

32%

18%

Point-to-Point Indian Sub-Continent Other International

Premium Class

25
41. In summary, the business model U.S. carriers have chosen gives them relatively little incentive to 

carry international traffic beyond Europe to the ISC (or even beyond the hub cities of their respective 

European partners). To the contrary, Etihad’s model focuses on getting U.S. consumers not just to Abu 

Dhabi (where U.S. carriers choose to not fly directly) but also to the Indian Subcontinent. As a result, by 

focusing their transatlantic operations on travel to Europe (to the extent that only 2 percent of Europebound U.S. traffic terminates in the ISC) U.S. carriers have signaled that the portions of their networks 

beyond Europe are not as valuable to them as those segments and routes on which they have valuable 

government-conferred antitrust immunity and/or competition law exemptions.

IX.ASSESSMENT OF ALLEGATION THAT CAPACITY GROWTH EXCEEDS GLOBAL GDP

GROWTH

42. The Open Skies Report states that Etihad and the other Gulf-based carriers are “adding [...] new 

capacity at rates that substantially exceed global GDP growth—which drives growth in demand for air 

transport services.”31 As a result, the Open Skies Report claims, “the only way to accomplish this feat is 

to continue taking passengers from other countries’ carriers.”32 Putting aside the notion that “taking 

passengers from other countries’ carriers”33 is consistent with precisely the kind of competitive process

that benefits consumers, the analysis presented in Figure 20 of the Open Skies Report relies on 

inappropriate data and flawed economic reasoning.

43. As an initial matter, an analysis of U.S. Department of Transportation data indicates that while 

Etihad has increased the number of available seats on flights between the U.S. and its hub in Abu Dhabi, 

its load factors have remained around 80 percent. For example, as Exhibit 14 shows, while Etihad 

increased the annualized number of total seats flown between U.S. and Abu Dhabi from 192,000 in 2009 

to 845,000 in 2014, the load factor actually increased (and was at or above 80 percent in the intermittent 

years).

31 Restoring Open Skies, p. 41.

32 Ibid.

33 Ibid.

26

 
EXHIBIT 14

ETIHAD’S ANNUALIZED CAPACITY AND LOAD FACTOR

ON FLIGHTS BETWEEN THE UNITED STATES AND ABU DHABI

NOVEMBER 2006 – OCTOBER 2014

Source: U.S. DOT Bureau of Transportation Statistics, Air Carrier Statistics: T-100 International Segments.

44. Further, the forward-looking analysis of supposedly “excessive expansion” by Etihad and the 

other Gulf-based carriers in the Open Skies Report essentially relies on a comparison of projected global 

Gross Domestic Product (“GDP”) growth between 2012 and 2020 to the growth rate of capacity for those 

carriers during the same period. That is, the annual 3 percent growth in global GDP appears to the 

authors of the Open Skies Report to be too low to justify the 11 percent annual growth in the capacity of 

Gulf-based carriers.

34

34 The estimates of capacity growth are from a thesis submitted by a student in MIT’s Master of Science in 

Transportation program. (Karim Al-Sayeh, The Rise of the Emerging Middle East Carriers: Outlook and 

Implications for the Global Airline Industry, Massachusetts Institute of Technology, June 2014.) We have not 

independently verified these estimates and do not represent that they are consistent with Etihad’s (or the other Gulf 

carriers’) own expectations about capacity growth. Rather, they are used here for the purpose of illustrating the 

underlying flaws of the analysis presented in the Open Skies Report.

51%

78%

73%

84% 83%

87%

80% 79%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

 -

 100,000

 200,000

 300,000

 400,000

 500,000

 600,000

 700,000

 800,000

 900,000

Nov2006 -

Oct2007

Nov2007 -

Oct2008

Nov2008 -

Oct2009

Nov2009 -

Oct2010

Nov2010 -

Oct2011

Nov2011 -

Oct2012

Nov2012 -

Oct2013

Nov2013 -

Oct2014

Capacity (Available Seats)

Capacity Load Factor

27

 
45. This comparison is fatally flawed as a matter of economics for a number of reasons. First, the 

worldwide measure of GDP provides little information about demand growth in areas where Gulf 

carriers’ U.S.-based traffic actually goes. In fact, as discussed above, a substantial portion of Etihad’s

U.S. traffic currently goes to (or from) the ISC and Southeast Asia. As a result, it is the expected growth 

demand of these regions—as opposed to worldwide demand—that is relevant for such an analysis.

46. Additionally, the analysis presented in the Open Skies Report entirely ignores the economic 

concept of income elasticity of demand, i.e., the relationship between changes in income and changes in 

the quantity demanded of a particular good, as represented by the formula below.

35 

IIIIIIIIIIII EEEEEEEEEEEE EEEEEE oo DD DD = % CCh aa DD DD

% CCh aa IIIIIIIIIIII

47. For example, if a 1 percent increase in income is expected to lead to a 2 percent increase in 

demand for air travel, the elasticity of demand equals 2.0; in this case, the demand for air travel is said to 

be elastic. Similarly, if demand for air travel is not particularly sensitive to changes in income (e.g., a 1 

percent change in income leads to only a 0.5 percent increase in demand, for an elasticity of 0.5), the 

demand is said to be inelastic. As a result, without applying this metric—which measures customers’ 

varied preference for different goods—a direct comparison of GDP growth to capacity expansion has no 

useful economic meaning.

48. A number of economic studies have analyzed income elasticity of demand for air travel services. 

For example, a study by the IATA estimated that long-haul demand elasticities in developing countries—

where Etihad conducts a substantial portion of its business—were approximately 2.0;36 i.e., demand for 

air travel would increase by 2 percent for every 1 percent increase in national income.

Exhibit 15, below provides a revised version of the analysis presented in Figure 20 of the Open Skies 

Report.

35 Nicholson, Walter, and David C. Stapleton. Microeconomic theory: basic principles and extensions, 2002, p. 178.

36 IATA, Air Travel Demand, IATA Economics Briefing No. 9, April 2008, Table 2.

28

 
EXHIBIT 15

REVISED ANALYSIS OF “GDP VERSUS AIRLINE CAPACITY GROWTH RATES”

FROM FIGURE 20 OF THE OPEN SKIES REPORT

Notes:

1 “Emerging and Developing Asia” is composed of 29 countries, including Bangladesh, India, Indonesia,

Malaysia, Nepal, Philippines, Sri Lanka, Thailand, and Vietnam.

2 “Implied Growth in Demand for Air Travel” is calculated by multiplying the GDP growth for “Emerging and 

Developing Asia” by an income elasticity of demand of 2.0.

Sources:

International Monetary Fund, World Economic Outlook Database, October 2014.

IATA, Air Travel Demand, IATA Economics Briefing No. 9, April 2008.

Restoring Open Skies Report, citing to: Karim Al-Sayeh, The Rise of the Emerging Middle East Carriers: Outlook 

and Implications for the Global Airline Industry, Massachusetts Institute of Technology, June 2014.

49. First, as this exhibit shows, the GDP in developing Asian economies (illustrated in the exhibit 

with an orange line)—where Etihad and the other Gulf carriers focus their U.S.-based traffic—is 

projected to grow at rates more than double those of the worldwide average (represented by the red line). 

Economic growth in individual countries on the ISC such as India, Bangladesh, Sri Lanka, and Pakistan 

(represented in the exhibit by dashed lines) generally have projected growth rates similar to the regional 

average. As a result, using the economic growth projections in the relevant region, combined with the 

0%

2%

4%

6%

8%

10%

12%

14%

2013 2014 2015 2016 2017 2018 2019

Growth Rate 

Emerging and Developing Asia Bangladesh India Sri Lanka Pakistan

Estimated Growth in Gulf Carriers' Capacity

Estimated Growth in Global GDP

29
appropriate elasticity factor of 2.0, the implied growth in demand for air travel services (represented in the 

exhibit by the blue line) is actually greater than the Gulf carriers’ estimated capacity expansion.

50. It is important to note that the explanation above is intended to illustrate the flawed and 

incomplete analysis presented in the Open Skies Report, rather than express a definitive view on the 

“correct” level of expansion. However, even with the revisions presented above, such a simplistic 

approach may fail to address other factors that may drive strategic decisions with respect to capacity 

expansion. For example, one issue the Open Skies Report fails to consider is the possibility of pent-up 

demand in the ISC. That is, in addition to expected future growth, capacity expansion may be planned to 

address the surplus demand that already exists in regions historically underserved by international 

carriers.37 Other factors unrelated to economic growth may be relevant as well. For example, a 2013 

report published by the U.S.-UAE Business Council identified “geographic centrality of the U.A.E” as 

“the most compelling”38 factor for Gulf carriers’ growth. Specifically, the report stated that “Dubai and 

Abu Dhabi are the new crossroads of the globe, perfectly situated to serve as connecting hubs for traffic 

moving between North America, South America, Europe and Africa to the west and south on one hand, 

and on the other the nearby Middle East, India and South Asia, China and the rest of East Asia, Southeast 

Asia, and Australia and New Zealand.”39 Additionally, this report noted “about 60 percent of the world’s 

population lives within six flying hours of the U.A.E.”40 Taken together, potential pent-up demand and

the “geographic centrality” of Etihad’s hub illustrate the types of factors ignored by the simplistic 

comparison of capacity growth and global GDP growth presented in the Open Skies Report.

X. ASSESSMENT OF ANALYSES IN THE COMPASS LEXECON REPORT

51. In addition to assessing certain claims in the Open Skies Report, we have also been asked by 

Etihad to conduct an initial review of the analyses and claims presented in the Compass Lexecon Report. 

37 As described above, arrangements between U.S. and European carriers provide little incentive to send traffic 

beyond Europe to the ISC.

38 U.S.-UAE Business Council, U.S.-U.A.E. Commercial Aviation: Taking Flight, 2013 (“Taking Flight Report”), p. 

3. (Available at http://usuaebusiness.org/wp-content/uploads/2013/03/US-UAE-aviation-report_Published.pdf, 

Accessed May 20, 2015)

39 Ibid.

40 Ibid. Notably, this report was authored by a Dr. Robert Britton, who for 20 years was an employee of American 

Airlines. (See http://www.airlearn.net/Rob%20Britton%20CV-Resume.pdf, Accessed May 20, 2015) Since the 

publication of the Open Skies Report, Dr. Britton appears to have cast doubt on his own research of the benefits of 

the U.S.-UAE aviation relationship. (See http://www.airlearn.net/Reconsidering-Mar2015.pdf, Accessed May 20, 

2015) However, to our knowledge, Dr. Britton has not reversed his position with respect to UAE’s “geographic 

centrality” as an important growth factor. 

30

 
The report presents what it refers to as a “basic analysis of passenger booking data,”41 as well as an

“econometric analysis.”42 At this time, the authors of the report have not made public either the data sets 

or the computer code used for conducting the econometric analyses in their report. As a result, we are 

currently limited to considering the models it describes and the results presented.

A. The Compass Lexecon Report Fails to Establish a Causal Link Between the Analyses it 

Presents and the Alleged Subsidies

52. The Compass Lexecon Report begins with the claim that “[c]ompelling evidence has recently 

emerged that [the Gulf carriers] have been the beneficiaries of over $40 billion dollars of state subsidies 

and other unfair advantages over the past decade.”43 As an initial matter, this appears to be an uncritical 

acceptance of the “evidence,” as we understand the nature of that evidence is currently under dispute.

Nonetheless, the Compass Lexecon Report’s claims that “U.S. carriers have suffered [traffic losses] as a 

result of Gulf carriers’ subsidized U.S. expansion.”44 This is a critical assumption, as it predicates the 

entirety of the claims in the Compass Lexecon Report. That is, the implication is that the results of their 

analyses—which look solely at changes in traffic volumes between various points—are caused entirely 

by the alleged subsidies. This “causal link” lacks any supporting evidence. For example, the Compass 

Lexecon Report fails to explain how the alleged presence of subsidies has caused U.S. carriers to “suffer 

traffic losses.” Rather, it simply points to the alleged “proliferation of subsidized Gulf carrier capacity to 

the United States”45 without explaining why the proliferation in and of itself would lead to U.S. carriers 

losing business.

53. As we have stated above,46 it is our understanding that the authors of the Open Skies Report have 

not alleged the existence of predatory pricing by Etihad and other Gulf-based carriers. Nor has the 

Compass Lexecon Report provided any analysis of prices. As a result, it has failed to provide any 

explanation or empirical support as to how the alleged subsidies have caused the results they have found. 

We discuss below why the analyses presented in the Compass Lexecon Report are fundamentally flawed. 

However, even taking those analyses at face value, none of them provide any explanation as to the 

mechanism by which the alleged subsidies affected U.S. carriers’ respective businesses.

41 Compass Lexecon Report, p. 4.

42 Id., p. 12.

43 Id., p. 1.

44 Id., p. 3. Emphasis added.

45 Ibid.

46 See footnote 26, supra.

31

 
54. To the contrary, we have developed an initial series of analyses that compare Etihad’s published

fares between its U.S. gateway cities and key destinations in the ISC to fares published by other carriers 

on these routes.47 Based on our analysis, we found that Etihad’s published economy class fares on routes 

between the U.S. and the ISC are close to or slightly lower than the median fares published by competing

carriers. However, it is also the case that the magnitudes of difference vary across routes, with Etihad 

being above the median fares published for some routes.

55. The importance of establishing causality when conducting economic analyses of antitrust and 

competition issues is well-established, and courts have criticized economists that failed to show how their 

models and results tied to the facts of the case at hand. For example, in Comcast Corp. v. Behrend, the 

Supreme Court of the United States stated that “any model supporting a plaintiff’s damages case must be 

consistent with its liability case, particularly with respect to the alleged anticompetitive effect of the 

violation.”48

56. Similarly, the notion of causality is paramount in economic analysis. For example, as one leading 

econometrics textbook put it, “the economist’s goal is to infer that one variable has a causal effect on 

another variable. Simply finding an association between two or more variables might be suggestive, but 

unless causality can be established, it is rarely compelling.”49 Additionally, as prominent econometrician 

(and Compass Lexecon affiliate) Dr. Daniel Rubinfeld explains in the Federal Judicial Center’s Reference 

Manual on Scientific Evidence:50

Causality cannot be inferred by data analysis alone; rather, one must infer that a causal 

relationship exists on the basis of an underlying causal theory that explains the 

relationship between the two variables. Even when an appropriate theory has been 

identified, causality can never be inferred directly. One must also look for empirical 

evidence that there is a causal relationship. Conversely, the fact that two variables are 

correlated does not guarantee the existence of a relationship; it could be that the model—

a characterization of the underlying causal theory—does not reflect the correct interplay 

among the explanatory variables.

47 See Section VII.A, supra.

48 Comcast Corp. v. Behrend, 569 U.S. (2013), citing ABA Section of Antitrust Law, Proving Antitrust Damages: 

Legal and Economic Issues 57, 62 (2d ed. 2010).

49 Wooldridge, Jeffery M., Introductory Econometrics: A Modern Approach. 4th ed. 2009, p. 12. (Emphasis in 

original)

50 Federal Judicial Center, Reference Manual on Scientific Evidence 432 (3d ed. 2011), p. 310.

32

 
Having failed to establish a causal link between the alleged subsidies and the outcomes of their analyses, 

the results presented in the Compass Lexecon Report do not support the main claim.

51

B. The Compass Lexecon Report Focuses Only On U.S.-International Passenger Traffic, 

Ignoring Key Evidence

57. As the title of the Compass Lexecon Report indicates, it provides an analysis of the impact that 

the alleged subsidies have had “on international passenger traffic to/from the United States.”52 As a 

result, it fails to paint a complete picture of competition on routes served by Etihad and other Gulf 

carriers, as it only looks at a selected sampling of capacity and traffic flow measures, while ignoring all

other information. In this report, we have conducted analyses of Etihad’s and U.S. carriers’ load 

factors,

53 as well as an initial analysis of published fares on key U.S.-ISC routes.54 We have also found

that in many instances, while competition may have reduced U.S. carriers’ shares of total traffic, the same 

U.S. carriers still served more passengers because the overall volume of travel expanded.55 However, the

Compass Lexecon Report—by design—ignores all of these contradictory data and facts. 

58. Notably, Compass Lexecon economists have previously provided consulting services for U.S. 

carriers, including advising on the consummated mergers, slot swaps, and similar transactions between (i) 

Delta Air Lines and Northwest Airlines in 2008,56 (ii) Delta Airlines and U.S. Airways in 2011,

57 and (iii)

U.S. Airways and American Airlines in 2013.

58 As part of their work in these matters, Compass Lexecon 

economists have described economic frameworks for assessing potential competitive effects in the airline 

industry, in large part focusing on the benefits or costs of changes in the competitive landscape to 

51 Notably, we have published work on the importance of causality in antitrust analysis: “it is the responsibility of a 

prudent economic expert to connect causally the complained-of actions to the decline in performance of the plaintiff, 

rather than simply point out their concurrency.” (Johnson, J. H., Michael Kheyfets, and Matthew Milner. “Causality 

and Damages Estimation in Antitrust Litigation: A Case Study.” Antitrust Report. Issue 1, 2011. Emphasis in 

original.)

52 Compass Lexecon Report, p. 1.

53 See Sections VIII and IX.

54 See Sections VIII.A and Appendix C.

55 See Sections VI and Appendix B.

56 See http://www.compasslexecon.com/highlights/delta-and-northwest-merger/?year=2008, Accessed on May 20, 

2015.

57 See http://www.compasslexecon.com/highlights/seagate-samsung-transaction/delta-air-lines-us-airways-slotswap/?year=2011, Accessed on May 20, 2015.

58 See http://www.compasslexecon.com/highlights/compass-lexecon-experts-provide-key-economic-advice-andanalyses-on-us-airways-and-american-airlines-merger/?year=2013, Accessed on May 20, 2015.

33

 
consumers. For example, in an analysis of the Delta/US Airways slot swap transaction, Compass 

Lexecon:

59

• Complained of the FAA “focusing on unsubstantiated, theoretical harms, while ignoring the clear and 

well-documented output expansion and consumer benefits.” (¶3)

• Highlighted their “analysis of the competitive effects of the transaction [that] examined the number of 

airport-to-airport routes and passengers immediately affected by the gain or loss of a competitor 

according to Delta’s and U.S. Airways’ proposed post-transaction schedules,” which apparently 

showed that “the net number of passengers benefitting from increased nonstop competition is 4.0 

million.” (¶4)

• Used “results on the relationship between fares and concentration from empirical literature” to show 

that “fares on routes with a change in non-stop competition following the transaction would fall, on 

net, by $44 million annually.” (¶4)

• Discussed an “analysis of consumer benefits [which] documented that, according to the parties'

proposed post-transaction schedules, the net seat capacity on arriving and departing flights will 

increase by 4.4 million annually at LGA and 2.5 million annually at DCA, reflecting the strongly procompetitive nature of the transaction. Due to this increased capacity as well as improved service, 

more passengers will choose Delta and U.S. Airways after the transaction than before.” (¶5)

• “Estimated the value to consumers from the capacity expansions and quality improvements due to the 

transaction to be $153 million annually.” (¶5)

• Stated that “because increasing competition generally enhances consumer welfare, even if it is

rough for the competitors involved, we assume that FAA has in mind a scenario in which Delta or

U.S. Airways drive the smaller carriers out of certain routes and then attempt to increase prices on 

those routes. However, FAA provides absolutely no evidence in support of such a scenario. Indeed, it 

is difficult to see the economic logic behind the claim.” (¶25)

These positions are notable because the authors in this matter appear to be taking views inconsistent with

those Compass Lexecon economists took in the Delta/US Airways transaction. Here, the Compass 

Lexecon has characterized output expansion as having a negative effect on competition, have conducted 

no evaluation of consumer benefits or improved service at all, and have not analyzed effects of the alleged 

conduct on fares. In fact, the last of the excerpts above appears to be the exact opposite of the position

U.S. carriers and their economists have taken in this matter.60 As Compass Lexecon economists pointed 

59 Non-Confidential Joint Appendix to Comments of Delta Air Lines, Inc. and U.S. Airways, Inc., March 22, 2010. 

(Emphasis added) Available at http://www.airlineinfo.com/faapdf2/208.pdf.

60 Notably, the word “consumer” does not appear at all in the body of the Compass Lexecon Report.

34

 
out in 2010, “it is unusual, to say the least, for a government agency to worry about the deleterious effects 

of increasing competition.”61

C. The Entirety of Analyses in the Compass Lexecon Report are Predicated on a False Notion 

That Etihad and Other Gulf Carriers Must “Stimulate Demand” in Order to be Allowed to 

Operate

59. A key concept introduced and repeated—but not defined in economic terms—in the Compass 

Lexecon Report is the notion that carriers “stimulate demand.”62 Before proceeding with our assessment 

of their analyses, it is important to address this notion, as the entirety of their conclusions are predicated 

on the claim that Gulf carriers have not “stimulated” demand. While the Compass Lexecon Report does 

not explain this concept, we understand it to mean servicing a customer who would not otherwise be 

serviced by U.S. carriers. 

60. This definition has no basis in economics. The Compass Lexecon Report fails to point to any 

economic or legal doctrine which indicates that an incumbent is entitled to the customers it serves and the 

only way for new entrants to compete “fairly” is to sell their products to customers who would not 

otherwise purchase from the incumbent. The nature of economic competition, as well as U.S. antitrust 

law, does not guarantee any such entitlement to maintaining a firm’s business forever; rather firms may

try to not only grow the size of the markets in which they operate, but also try to attract their competitors’ 

customers through lower pricing and higher quality products.

61. Importantly, U.S. competition laws are concerned with protection of competition, not individual 

competitors. As the U.S. Department of Justice has stated:63

The focus on protecting the competitive process has special significance in 

distinguishing between lawful and unlawful unilateral conduct. Competition produces 

injuries; an enterprising firm may negatively affect rivals’ profits or drive them out of 

business. But competition also benefits consumers by spurring price reductions, better 

quality, and innovation. Accordingly, mere harm to competitors is not a basis for antitrust 

liability. “The purpose of the [Sherman] Act,” the Supreme Court instructs, “is not to 

protect businesses from the working of the market; it is to protect the public from the 

failure of the market.” Thus, preserving the rough-and tumble of the marketplace 

ultimately “promotes the consumer interests that the Sherman Act aims to foster.”

61 Ibid., ¶24. (Emphasis in original)

62 Compass Lexecon Report, p. 2.

63 U.S. Dep't of Justice, Competition and Monopoly: Single-Firm Conduct Under Section 2 of the Sherman Act 

(2008), Chapter 1, Section III.D. (Emphasis added) Available at: 

http://www.justice.gov/atr/public/reports/236681_chapter1.pdf

35

 
However, the Compass Lexecon Report contains no analysis of competition, but only the alleged effects

of competition on the U.S. carriers. That is, when it claims that its analyses “demonstrate that subsidized 

Gulf carrier expansion to the United States has directly harmed U.S. carriers and their JV partners,”64 that 

is a finding—even if it were true—that is irrelevant to an economic analysis of alleged anticompetitive 

acts.

D. The “Basic Analysis” in the Compass Lexecon Report Has Substantial Problems

62. The “basic analysis” in the Compass Lexecon Report begins with the claim that “Gulf carriers 

have failed to meaningfully stimulate additional local traffic to/from their hub cities.”65 First, this 

analysis does not actually present capacity and growth in traffic for Etihad, and it is unclear if the analysis 

shown (i.e., just for Emirates) is intended to be representative of the other Gulf carriers. As we discussed 

above, bookings between the U.S. and Abu Dhabi have grown substantially in recent years.66 Further, as 

we have also discussed above, it is inappropriate and misleading to compare Etihad’s capacity on flights 

between U.S. and Abu Dhabi to the number of passengers that terminate their trip there because Etihad’s 

passenger flow generally continues beyond its domestic hub, primarily to the ISC. For example, as 

Exhibit 13 shows, while only 14 percent of Etihad’s economy class traffic between March 2014 and 

February 2015 terminated in Abu Dhabi, 66 percent proceeded beyond its hub to the ISC.

63. Notably, the authors of the Compass Lexecon Report have failed to conduct any analysis of load 

factors to test whether the apparently vast differences between capacity and bookings on flights between 

the U.S. and Gulf carriers’ hubs has resulted in “excess” capacity.67 In fact, as we showed in Exhibit 14, 

while Etihad has increase the number of total seats flown between U.S. and Abu Dhabi over the relevant 

period, the load factor on this route actually increased.

64. Potentially recognizing the importance of the “beyond the hub” destinations, the Compass 

Lexecon Report purports to conduct an analysis of that travel as well. However, it does not actually

present any analysis of the changes in traffic volume traveling from the U.S. to key “beyond” destinations. 

Rather, it simply restates the claim made in the Open Skies Report that “Gulf carriers have grown their 

share of U.S.-Indian Subcontinent bookings from approximately 12% in 2008 to 40% in 2014.”68 As we 

showed in Exhibit 2, the overall volume of economy class travel between U.S. and ISC has grown 

64 Compass Lexecon Report, p. 20.

65 Id., p. 5.

66 See ¶12, supra.

67 See Compass Lexecon Report, Exhibit 3.

68 Id., p. 9.

36

 
substantially since 2009. (Analyses in Appendix A show the same pattern for premium class travel and 

for individual routes within the ISC.) Further, as Exhibit 6 shows, while the Immunized Alliance 

Members lost 4.4 percentage points of the overall volume of economy class traffic on this route between 

2009 and 2014 (reducing their share from 40.7 to 36.3 percent), they actually serviced 18 percent (or over 

223,000) more passengers.

65. The “basic analysis” in the Compass Lexecon Report also claims that “if it were true that Gulf 

carriers’ services stimulated significant amounts of new traffic [between the U.S. and ISC] one would 

expect to see faster traffic growth [on those routes] than between [China and South Korea].”69 However, 

the Compass Lexecon Report fails to explain why “one would expect” that the aggregate of travel 

between U.S. and China/South Korea is a meaningful or appropriate benchmark. Additionally, this 

analysis ignores all other aspects of the competitive landscapes on the respective individual routes.

70

66. Lastly, the Compass Lexecon Report finds it “unsurprising” that the Gulf carriers have allegedly 

“failed to meaningfully stimulate additional traffic” because “all but a small handful of the destinations 

served by the Gulf carriers are already served by U.S. carriers and/or their non-Gulf carrier global 

alliance partners.”71 That is, they claim, because the Gulf carriers’ respective networks are “highly 

redundant” and “largely duplicative.”72 This claim has no economic foundation. In the next section, we 

discuss in detail the assumption made by U.S. carriers (and their economists) that competitors should not 

operate anywhere where a U.S. carrier already offers service. One key implication of this claim is that 

any two carriers operating in the same location are “redundant” and that any new entry of competition is 

“largely duplicative.”

E. The Regression Analyses in the Compass Lexecon Report Have Substantial Problems

67. The Compass Lexecon Report purports to “formally test how Gulf carrier expansion to the United 

States has affected passenger traffic levels on city-pairs to/from the United States” by estimating “a series 

69 Compass Lexecon Report, p. 10.

70 Notably, as we discuss below, even the regression analyses in the Compass Lexecon Report does not attempt to 

control for all other sources of competition beside that from the Gulf carriers. Moreover, even taking this analysis at 

face value, it indicates that travel between the ISC and Dallas/Ft. Worth, Philadelphia, and Washington grew faster

than travel between those U.S. cities and China and South Korea. To the extent this analysis serves as basis for 

Compass Lexecon Report’s conclusions, their own findings indicate that demand for travel to and from those cities 

was supposedly “stimulated” beyond levels for China and South Korea.

71 Compass Lexecon Report, p. 11. (Emphasis added)

72 Ibid.

37

 
of passenger traffic regression models.”73 As we discussed above, at this time, we do not have access to 

either the data sets or the computer code used in generating the econometric analyses in the Compass 

Lexecon Report, and therefore only offer conceptual critiques to the models described and the results 

presented in the report.

68. As an initial matter, it is important to explain a series of fundamental features of the Compass 

Lexecon Report regression models: Specifically, they:

• Treat all U.S. carriers (and in some variations, the U.S. carriers and their immunized partners) as 

though they are a single entity. That is, these models have no ability to discern the competition (if 

any) between U.S. carriers (and their immunized partners).

• Contain no controls for the presence of any other competitors on any route. That is, to the extent 

non-Gulf-based carriers compete on the same routes, the effect of those competitors would be 

ascribed to Etihad and the other Gulf carriers. For example, Air India and Turkish Airlines, among 

others, compete substantially for U.S.-India traffic, a fact for which the Compass Lexecon models do 

not account.

• Include “all city-pairs between the continental United States and destinations in Asia, Africa, Europe, 

the Middle East and Australasia, with the exception of city-pairs to and from Milan.”74 As we have 

shown in Exhibit 13, approximately 80 percent of Etihad’s traffic either terminates in Abu Dhabi or 

goes to the ISC. This means that the model includes a substantial number of routes (most notably, 

between the U.S. and Europe) where Etihad does not materially compete for U.S. traffic—and 

therefore could not have caused the effects the Compass Lexecon Report purports to find.75

• Purport to test how “Gulf carrier expansion to the United States has affected passenger traffic levels 

on city-pairs to/from the United States.”76 However, their model reports only a single average effect 

across all city-pairs. That is—to the extent the results of the Compass Lexecon regression model 

provide meaningful information—if the effect actually exists on one route but not on another, the 

model is structured in a way such that it cannot make that distinction.77

73 Id., p. 12.

74 Id., p. 13.

75 The regressions also arbitrarily exclude “city-pairs to and from Milan” on the basis that “Emirates’ entry between 

New York City and Milan has resulted in overcapacity on this city-pair.” (Compass Lexecon Report, p. 13.) No 

analysis is presented to substantiate the claim of “overcapacity” on this route, nor is it clear why all other city-pairs 

to and from Milan other than New York are excluded.

76 Compass Lexecon Report, p. 12.

77 The Compass Lexecon Report acknowledges this averaging across routes in footnote 29.

38

 
69. There is also a fundamental flaw with the “key independent variable of interest” in the Compass 

Lexecon model, which is intended to represent a count of the “Number of Gulf Carriers Present” on a 

particular route.78 In this model, a Gulf carrier is determined to be “serving” a city-pair in a given quarter 

if it “had at least a 3% share of bookings in the quarter.”79 This variable (i.e., there are either zero, one, 

two, or three Gulf carriers “present” on a city-pair in the given quarter) is problematic for a number of 

reasons:

• The thresholds (either 3 or 10 percent share of bookings) are arbitrary. The Compass Lexecon Report

provides no explanation as to how a carrier with a little as 3 percent of bookings can cause the effects

the regression model purports to measure. (Additionally, it provides no explanation as to why a 

carrier with as little as 3 percent of bookings is treated equally as another carrier with a potentially 

much larger share.)

• Because the Compass Lexecon regression models do not account for any competitive alternatives 

other than the Gulf carriers—nor do they reflect actual evidence on when carriers began operating on 

a particular route—the formulation of this variable makes it appear that carriers “enter” and “exit” a 

particular route when they in fact do not. For example, using the 3 percent threshold for “presence” 

on a route described in the Compass Lexecon Report, Etihad appears to leave and re-enter the New 

York City to Delhi route several times over the span of 2008 to 2014, and appears to be “not present” 

on the route for approximately half of the time. However, factual evidence indicates that Etihad has 

been operating on this route for the entire period of study,80 meaning that the “presence” of Gulf 

carriers as defined by the model is contrary to the facts.

70. The Compass Lexecon regression models purports to test two theories, discussed in turn below.

• “Gulf carriers’ traffic gains on city-pairs to/from the United States have come at the expense of 

U.S. and other carriers.”81

71. The Compass Lexecon Report claims that this regression analysis “clearly demonstrates that Gulf 

carriers’ subsidized capacity growth to the United States has come at the expense of U.S. and other 

78 Compass Lexecon Report, p. 13.

79 Ibid. (An additional sensitivity of this model appears to have also been run where the threshold for “serving” is 

10 rather than 3 percent.)

80 Felicity Cousins, Etihad to fly Abu Dhabi – JKF, Business Traveller. (July 27, 2006), 

http://www.businesstraveller.com/news/etihad-to-fly-abu-dhabi-jfk. Accessed May 20, 2015.

Etihad Airways begins India Operations, The Hindu Business Line. (Sep. 29, 2004), 

http://www.thehindubusinessline.com/2004/09/30/stories/2004093002970600.htm.

81 Compass Lexecon Report, p. 13.

39

 
carriers.”82 In addition to the conceptual and operational problems with this model, as discussed above, 

the supposed finding that “presence of Gulf carriers on a city-pair has resulted in the diversion of 

passengers away from non-Gulf carriers to the Gulf carriers in that city-pair”83 is at best an indication that 

competition exists.

84 Additionally, as our analysis in Exhibit 6 indicates (and is further supplemented by 

similar analyses in Appendix B), as traffic between the U.S. and key regions where Etihad operates has 

grown over time, the numbers of passengers served by U.S. carriers (and their immunized partners) have 

also grown. The fact that Gulf-based carriers’ share may have grown faster on some routes is of no 

consequence in the absence of any link to any alleged anticompetitive conduct.

• “Gulf carriers have failed to meaningfully stimulate additional traffic above and beyond what 

would be expected based on changes in the city-pair’s underlying demand.”85

72. This is essentially the same model as that previously described, which purports to find that 

“presence” of Gulf carriers has reduced traffic carried by U.S. carriers and their partners. The problem 

with this model is that it measures an average effect across all routes, including many between U.S. and 

Europe (as well as other continents) where Etihad does not compete for traffic. As a result, it is unable to 

determine whether, in fact, Etihad (and other Gulf-based carriers) have “stimulated” demand on relevant 

routes. Moreover, the Compass Lexecon Report provides no explanation as to why Etihad is responsible

for “stimulating demand” between the U.S. and the rest of the world on routes where it does not compete. 

73. This model is also predicated on the notion that Etihad (and other Gulf-based carriers) are only 

permitted to compete with U.S. carriers and their immunized partners if they “stimulate” demand “above 

and beyond”86 that generated by what the authors characterize as general economic drivers of demand for 

international air travel (i.e., population and income growth).87 This appears to imply that Gulf carriers 

82 Id., p. 18. (Emphasis added)

83 Id., pp.14-15. (Emphasis in original)

84 In fact, it is likely that this model would have the same findings on any route where U.S. carriers have lost 

passengers as a result of growth from non-Gulf-based carriers. Moreover, to the extent U.S. carriers compete with 

each other, the model is likely to find that “presence” of one U.S. carrier “diverts” passengers from the others. 

Models that yield such “false positive” results are highly problematic and have been criticized by courts assessing 

antitrust and competition issues. (See e.g., In Re: Rail Freight Fuel Surcharge Antitrust Litigation, Appeal from the 

United States District Court for the District of Columbia (2013))

85 Compass Lexecon Report, p. 13. (Emphasis added)

86 Ibid.

87 Notably, Compass Lexecon’s own model finds a positive and statistically significant “stimulation from the 

presence of each Gulf carrier in city-pairs to/from Gulf carriers’ non-gateway U.S. cities.” (Compass Lexecon

Report, pp. 21-22 and Exhibit 9). That is, even by their definition, Gulf carriers “stimulated” demand for U.S. 

carriers’ domestic business (i.e., transporting passengers from hubs to their final destinations). However, while the 

40

 
can operate only on routes U.S. carriers choose not to serve (either by not setting fares sufficiently low for 

passengers to be able to purchase tickets, or by not serving certain destinations). If the demand for 

international air travel increases as populations grow and become wealthier, air carriers can choose to 

service that demand. However, the implication that “fair competition” can only take place when new 

entrants solely sell their products to customers who do not want to (or cannot) purchase those products 

from the incumbents is unsubstantiated and without merit. 

74. Ultimately, the Compass Lexecon Report concludes that the aggregate of the analyses it presents

lead to “one incontrovertible conclusion: Gulf carriers’ subsidized expansion has come almost entirely at 

the expense of U.S. and other carriers.”88 As we have shown in this report, this conclusion is far from 

“incontrovertible.” Rather, it is based on analyses that (i) have not been shown to have any causal link to 

the alleged subsidies, (ii) rely solely on U.S.-international passenger traffic and ignore other relevant 

evidence, (iii) are predicated on the notion that in order to compete, new entrants must “stimulate 

demand” by serving only customers not already served by an incumbent. This conclusion is further based 

on regression models that are fundamentally flawed and, at best, indicate the presence of competition.

Compass Lexecon Report dismisses this finding, referring to it as “minimal stimulation,” it fails to provide any 

benchmark for what level of “demand stimulation” should be considered appropriate.

88 Compass Lexecon Report, p. 22. (Emphasis in original)

41

 
APPENDIX A
FIGURE A1

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND MIDDLE EAST

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

3 Middle East includes Bahrain, Iran, Iraq, Jordan, Kuwait, Lebanon, Oman, Qatar, Saudi Arabia, Syrian Arab Republic, Yemen, and United Arab Emirates. 

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A2

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND BANGLADESH

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A3

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND INDIA

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A4

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND PAKISTAN

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A5

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND SRI LANKA

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A6

VOLUME OF TRAVEL BETWEEN CHICAGO AND HYDERABAD

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A7

VOLUME OF TRAVEL BETWEEN LOS ANGELES AND COLOMBO

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A8

VOLUME OF TRAVEL BETWEEN NEW YORK AND COLOMBO

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A9

VOLUME OF TRAVEL BETWEEN NEW YORK AND DELHI

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A10

VOLUME OF TRAVEL BETWEEN NEW YORK AND DHAKA

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A11

VOLUME OF TRAVEL BETWEEN NEW YORK AND HYDERABAD

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A12

VOLUME OF TRAVEL BETWEEN NEW YORK AND ISLAMABAD

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A13

VOLUME OF TRAVEL BETWEEN NEW YORK AND MUMBAI

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A14

VOLUME OF TRAVEL BETWEEN SAN FRANCISCO AND DELHI

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A15

VOLUME OF TRAVEL BETWEEN SAN FRANCISCO AND MUMBAI

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A16

VOLUME OF TRAVEL BETWEEN WASHINGTON D.C. AND DHAKA

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A17

VOLUME OF TRAVEL BETWEEN WASHINGTON D.C. AND ISLAMABAD

BY CARRIER GROUP

ECONOMY CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A18

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND INDIAN SUB-CONTINENT

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

3

Indian Sub-Continent includes Bangladesh, India, Pakistan, and Sri Lanka. 

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A19

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND MIDDLE EAST

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

3 Middle East includes Bahrain, Iran, Iraq, Jordan, Kuwait, Lebanon, Oman, Qatar, Saudi Arabia, Syrian Arab Republic, Yemen, and United Arab Emirates. 

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A20

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND BANGLADESH

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A21

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND INDIA

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A22

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND PAKISTAN

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A23

VOLUME OF TRAVEL BETWEEN THE UNITED STATES AND SRI LANKA

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A24

VOLUME OF TRAVEL BETWEEN CHICAGO AND HYDERABAD

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A25

VOLUME OF TRAVEL BETWEEN LOS ANGELES AND COLOMBO

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A26

VOLUME OF TRAVEL BETWEEN NEW YORK AND COLOMBO

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A27

VOLUME OF TRAVEL BETWEEN NEW YORK AND DELHI

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A28

VOLUME OF TRAVEL BETWEEN NEW YORK AND DHAKA

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A29

VOLUME OF TRAVEL BETWEEN NEW YORK AND HYDERABAD

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A30

VOLUME OF TRAVEL BETWEEN NEW YORK AND ISLAMABAD

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A31

VOLUME OF TRAVEL BETWEEN NEW YORK AND MUMBAI

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A32

VOLUME OF TRAVEL BETWEEN SAN FRANCISCO AND DELHI

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A33

VOLUME OF TRAVEL BETWEEN SAN FRANCISCO AND MUMBAI

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A34

VOLUME OF TRAVEL BETWEEN WASHINGTON D.C. AND DHAKA

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
FIGURE A35

VOLUME OF TRAVEL BETWEEN WASHINGTON D.C. AND ISLAMABAD

BY CARRIER GROUP

PREMIUM CLASS

MARCH 2009 – FEBRUARY 2015

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of Antitrust Immunity Cases.

2 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).
APPENDIX B
TABLE B1

SUMMARY OF CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN UNITED STATES AND KEY REGIONS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Indian Sub-Continent includes Bangladesh, India, Pakistan, Sri Lanka, and Nepal. 

Middle East includes Bahrain, Iran, Iraq, Jordan, Kuwait, Lebanon, Oman, Qatar, Saudi Arabia, Syrian Arab 

Republic, Yemen, and United Arab Emirates. 

4 Traffic flows are non-directional.

Sources: 

MIDT; U.S. DOT Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 41308-42309 (July 2014).

Bookings Share of Bookings

Percentage

Difference Point

Cabin Region 2009 2014 Count Percent 2009 2014 Difference

[a] [b] [c] [d] [e] = [d]-[c] [f] = [e]/[c] [g] [h] [i] = [h]-[g]

Economy Indian Sub-Continent 1,218,094 1,441,831 223,737 18.4% 40.7% 36.3% -4.4%

Economy India 1,161,761 1,338,389 176,629 15.2% 45.5% 39.7% -5.8%

Economy Middle East 1,134,220 1,119,896 -14,324 -1.3% 73.6% 47.3% -26.3%

Economy Pakistan 40,108 93,347 53,240 132.7% 13.5% 25.6% 12.2%

Economy Sri Lanka 6,531 6,493 -38 -0.6% 22.4% 11.8% -10.5%

Economy Bangladesh 9,695 3,602 -6,093 -62.8% 8.6% 2.0% -6.7%

Premium Indian Sub-Continent 123,948 157,752 33,805 27.3% 54.3% 41.8% -12.5%

Premium Middle East 133,594 147,418 13,825 10.3% 56.5% 32.7% -23.8%

Premium India 114,958 145,008 30,051 26.1% 58.8% 44.0% -14.8%

Premium Pakistan 6,796 11,666 4,871 71.7% 27.3% 41.4% 14.1%

Premium Sri Lanka 804 771 -33 -4.1% 25.2% 8.6% -16.6%

Premium Bangladesh 1,391 307 -1,084 -77.9% 29.4% 3.0% -26.4%
FIGURE B1

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN NEW YORK AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

ECONOMY CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

4 Lahore and Islamabad are not shown. Immunized Carriers served 15,317 more passengers between New York 

and Lahore in 2014 than 2009, constituting an increase of 3,200 percent; they served 8,169 more passengers 

between New York and Islamabad in 2014 than 2009, constituting an increase of 1,400 percent. The 

corresponding increases in shares of overall travel were 19 and 25 percentage points, respectively.

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Bangalore

7,383

Beirut

7,229

Dubai

5,597

Amman

-16,072

Delhi

41,122

Mumbai

36,807

Chennai

11,912

Hyderabad

4,704

-100%

-50%

0%

50%

100%

150%

200%

-10% -5% 0% 5% 10% 15% 20% 25% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
FIGURE B2

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN NEW YORK AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

PREMIUM CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Bangalore

1,547

Dubai

Beirut 1,246

1,086

Riyadh

547

Hyderabad

294

Delhi

9,930

Mumbai

9,846

Abu Dhabi

1,107

Chennai

1,052

Amman

-677

-60%

-40%

-20%

0%

20%

40%

60%

80%

100%

120%

140%

160%

-20% -15% -10% -5% 0% 5% 10% 15% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
TABLE B2

SUMMARY OF CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN NEW YORK AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional.

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Bookings Share of Bookings

Percentage

Difference Point

Cabin City 2009 2014 Count Percent 2009 2014 Difference

[a] [b] [c] [d] [e] = [d]-[c] [f] = [e]/[c] [g] [h] [i] = [h]-[g]

Economy Delhi 83,933 125,055 41,122 49.0% 40.5% 46.1% 5.6%

Economy Mumbai 68,682 105,488 36,807 53.6% 34.2% 43.4% 9.3%

Economy Amman 74,081 58,009 -16,072 -21.7% 96.8% 91.7% -5.1%

Economy Beirut 23,326 30,554 7,229 31.0% 87.3% 86.5% -0.9%

Economy Bangalore 18,010 25,392 7,383 41.0% 38.3% 37.5% -0.8%

Economy Chennai 7,120 19,031 11,912 167.3% 8.7% 25.8% 17.1%

Economy Lahore 479 15,795 15,317 3200.9% 0.5% 19.4% 18.8%

Economy Hyderabad 10,934 15,637 4,704 43.0% 13.8% 15.5% 1.7%

Economy Dubai 7,984 13,581 5,597 70.1% 14.2% 13.5% -0.7%

Economy Islamabad 584 8,752 8,169 1399.9% 2.0% 26.9% 25.0%

Premium Delhi 10,814 20,743 9,930 91.8% 44.0% 52.1% 8.1%

Premium Mumbai 10,868 20,713 9,846 90.6% 34.3% 44.7% 10.4%

Premium Bangalore 3,925 5,471 1,547 39.4% 55.5% 41.5% -14.0%

Premium Beirut 2,958 4,043 1,086 36.7% 96.0% 90.5% -5.5%

Premium Dubai 2,576 3,822 1,246 48.4% 12.1% 10.6% -1.4%

Premium Amman 3,929 3,252 -677 -17.2% 89.4% 94.5% 5.1%

Premium Chennai 1,443 2,494 1,052 72.9% 24.3% 32.1% 7.8%

Premium Abu Dhabi 879 1,985 1,107 126.0% 10.4% 12.0% 1.7%

Premium Hyderabad 1,647 1,941 294 17.9% 33.9% 22.1% -11.8%

Premium Riyadh 1,134 1,680 547 48.2% 27.2% 16.0% -11.1%
FIGURE B3

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN CHICAGO AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

ECONOMY CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Amman

+15,579

Abu Dhabi

+5,737

Jeddah

+1,016 Beirut

+704

Delhi

-31,327

Hyderabad

-10,643

Dubai

-6,480

Bangalore

-3,338

Chennai

-1,577 Mumbai

3457.5

-150%

-100%

-50%

0%

50%

100%

150%

200%

250%

300%

350%

-80% -70% -60% -50% -40% -30% -20% -10% 0% 10% 20% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
FIGURE B4

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN CHICAGO AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

PREMIUM CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Riyadh

531

Doha

184

Abu Dhabi

105

Delhi

-7,446

Dubai

-1,016

Bangalore

-795

Hyderabad

-603

Mumbai

-126

Chennai

-80

Amman

-147

-100%

-80%

-60%

-40%

-20%

0%

20%

40%

60%

80%

100%

-80% -70% -60% -50% -40% -30% -20% -10% 0% 10% 20% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
TABLE B3

SUMMARY OF CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN CHICAGO AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional.

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Bookings Share of Bookings

Percentage

Difference Point

Cabin City 2009 2014 Count Percent 2009 2014 Difference

[a] [b] [c] [d] [e] = [d]-[c] [f] = [e]/[c] [g] [h] [i] = [h]-[g]

Economy Amman 57,103 72,682 15,579 27.3% 96.1% 95.9% -0.2%

Economy Delhi 58,144 26,817 -31,327 -53.9% 70.3% 33.7% -36.5%

Economy Mumbai 19,708 23,165 3,458 17.5% 43.4% 43.6% 0.2%

Economy Bangalore 17,873 14,535 -3,338 -18.7% 75.9% 40.4% -35.4%

Economy Chennai 16,003 14,426 -1,577 -9.9% 52.5% 32.1% -20.4%

Economy Beirut 11,066 11,770 704 6.4% 89.8% 86.6% -3.2%

Economy Hyderabad 20,495 9,852 -10,643 -51.9% 35.2% 12.3% -22.9%

Economy Abu Dhabi 2,194 7,931 5,737 261.5% 35.3% 27.6% -7.6%

Economy Jeddah 6,339 7,355 1,016 16.0% 85.9% 50.7% -35.2%

Economy Dubai 13,350 6,870 -6,480 -48.5% 92.3% 27.8% -64.5%

Premium Delhi 10,771 3,325 -7,446 -69.1% 86.2% 33.5% -52.7%

Premium Bangalore 3,609 2,814 -795 -22.0% 93.3% 50.6% -42.7%

Premium Mumbai 2,805 2,679 -126 -4.5% 57.1% 42.9% -14.2%

Premium Amman 2,764 2,617 -147 -5.3% 96.1% 98.7% 2.6%

Premium Dubai 2,704 1,688 -1,016 -37.6% 91.5% 27.0% -64.5%

Premium Chennai 1,702 1,622 -80 -4.7% 79.9% 45.0% -34.9%

Premium Abu Dhabi 1,329 1,433 105 7.9% 47.0% 20.0% -27.0%

Premium Riyadh 853 1,384 531 62.3% 86.0% 60.3% -25.8%

Premium Hyderabad 1,751 1,148 -603 -34.4% 72.5% 24.2% -48.3%

Premium Doha 719 902 184 25.5% 80.1% 21.2% -58.9%
FIGURE B5

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN DALLAS AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

ECONOMY CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Beirut

846

Riyadh

746

Amman

152

Bangalore

70

Hyderabad

-4,825

Dubai

-4,538

Bahrain

-1,240

Mumbai

-897

Chennai

-191

Delhi

-25

-80%

-60%

-40%

-20%

0%

20%

40%

60%

80%

100%

-100% -90% -80% -70% -60% -50% -40% -30% -20% -10% 0% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
FIGURE B6

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN DALLAS AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

PREMIUM CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Delhi

469

Riyadh

428

Bangalore

143

Chennai

117

Abu Dhabi

22

Hyderabad

18

Dubai

-401

Bahrain

-142

Doha

-108

Mumbai

-94

-100%

-50%

0%

50%

100%

150%

200%

-100% -90% -80% -70% -60% -50% -40% -30% -20% -10% 0% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
TABLE B4

SUMMARY OF CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN DALLAS AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional.

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Bookings Share of Bookings

Percentage

Difference Point

Cabin City 2009 2014 Count Percent 2009 2014 Difference

[a] [b] [c] [d] [e] = [d]-[c] [f] = [e]/[c] [g] [h] [i] = [h]-[g]

Economy Mumbai 12,402 11,505 -897 -7.2% 90.8% 41.1% -49.8%

Economy Delhi 11,213 11,188 -25 -0.2% 93.1% 48.5% -44.6%

Economy Bangalore 8,529 8,598 70 0.8% 93.0% 47.7% -45.3%

Economy Chennai 7,728 7,537 -191 -2.5% 79.6% 34.4% -45.3%

Economy Hyderabad 10,554 5,729 -4,825 -45.7% 87.9% 17.1% -70.8%

Economy Amman 4,076 4,228 152 3.7% 98.0% 78.4% -19.6%

Economy Beirut 3,354 4,199 846 25.2% 99.8% 79.0% -20.8%

Economy Dubai 7,718 3,180 -4,538 -58.8% 93.9% 8.6% -85.3%

Economy Bahrain 4,231 2,991 -1,240 -29.3% 74.0% 53.0% -21.1%

Economy Riyadh 1,160 1,906 746 64.3% 97.2% 40.9% -56.2%

Premium Bangalore 1,193 1,335 143 11.9% 97.9% 45.4% -52.6%

Premium Delhi 807 1,276 469 58.1% 95.7% 45.7% -50.0%

Premium Abu Dhabi 872 893 22 2.5% 95.5% 55.5% -40.0%

Premium Mumbai 971 877 -94 -9.7% 91.6% 29.5% -62.1%

Premium Dubai 1,149 748 -401 -34.9% 89.5% 9.7% -79.8%

Premium Riyadh 299 727 428 143.1% 96.3% 72.3% -24.0%

Premium Chennai 421 537 117 27.7% 94.1% 28.4% -65.6%

Premium Hyderabad 420 438 18 4.3% 97.7% 20.6% -77.1%

Premium Bahrain 515 373 -142 -27.5% 96.7% 58.5% -38.2%

Premium Doha 423 315 -108 -25.4% 80.2% 20.0% -60.3%
FIGURE B7

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN LOS ANGELES AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

ECONOMY CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Riyadh

+3,110

Kuwait

+2,851

Amman

+2,374

Abu Dhabi

+2,096

Delhi

+2,060

Tehran

-25,578

Mumbai

-6,072

Bangalore

-839 Dubai

-656

Beirut

5,575

-150%

-100%

-50%

0%

50%

100%

150%

200%

250%

300%

-80% -60% -40% -20% 0% 20% 40% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
FIGURE B8

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN LOS ANGELES AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

PREMIUM CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Riyadh

1,729

Beirut

856

Delhi

739 Kuwait

627

Abu Dhabi

529 Doha

448

Jeddah

228

Dubai

106

Mumbai

80

Tehran

-780

-100%

-50%

0%

50%

100%

150%

200%

250%

300%

350%

-90% -80% -70% -60% -50% -40% -30% -20% -10% 0% 10% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
TABLE B5

SUMMARY OF CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN LOS ANGELES AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional.

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Bookings Share of Bookings

Percentage

Difference Point

Cabin City 2009 2014 Count Percent 2009 2014 Difference

[a] [b] [c] [d] [e] = [d]-[c] [f] = [e]/[c] [g] [h] [i] = [h]-[g]

Economy Delhi 30,571 32,631 2,060 6.7% 54.9% 42.4% -12.6%

Economy Mumbai 27,068 20,996 -6,072 -22.4% 53.4% 43.2% -10.2%

Economy Beirut 14,834 20,408 5,575 37.6% 75.2% 83.7% 8.5%

Economy Amman 10,581 12,955 2,374 22.4% 90.1% 78.7% -11.4%

Economy Tehran 36,865 11,287 -25,578 -69.4% 70.6% 15.9% -54.7%

Economy Kuwait 3,259 6,109 2,851 87.5% 85.6% 41.3% -44.3%

Economy Riyadh 2,131 5,241 3,110 145.9% 73.6% 20.7% -53.0%

Economy Bangalore 5,821 4,982 -839 -14.4% 41.7% 24.4% -17.2%

Economy Dubai 5,495 4,839 -656 -11.9% 23.8% 8.0% -15.8%

Economy Abu Dhabi 976 3,071 2,096 214.8% 87.6% 20.5% -67.1%

Premium Riyadh 611 2,340 1,729 283.0% 52.2% 28.9% -23.3%

Premium Beirut 1,336 2,192 856 64.1% 95.7% 93.6% -2.1%

Premium Delhi 1,432 2,170 739 51.6% 50.0% 33.0% -16.9%

Premium Mumbai 1,805 1,885 80 4.4% 50.8% 28.5% -22.4%

Premium Kuwait 859 1,485 627 73.0% 72.0% 36.1% -35.9%

Premium Dubai 1,298 1,403 106 8.1% 16.1% 7.0% -9.2%

Premium Tehran 1,860 1,080 -780 -41.9% 75.3% 28.3% -47.1%

Premium Abu Dhabi 426 955 529 124.2% 84.4% 14.3% -70.1%

Premium Doha 413 860 448 108.5% 50.5% 21.6% -28.9%

Premium Jeddah 605 833 228 37.7% 84.4% 22.2% -62.2%
FIGURE B9

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN SAN FRANCISCO AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

ECONOMY CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Riyadh

1,113

Dubai

39

Hyderabad

-2,932

Tehran

-1,825

Delhi

44,102

Bangalore

8,330

Mumbai

3,989

Chennai

2,501

Beirut

2,426

Amman

1,883

-100%

-50%

0%

50%

100%

150%

200%

-30% -20% -10% 0% 10% 20% 30% 40% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
FIGURE B10

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN SAN FRANCISCO AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

PREMIUM CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Delhi

1,077

Bangalore

616

Mumbai

464

Dubai

215

Chennai

35

Hyderabad

-342

Tehran

-43

Riyadh

499

Beirut

330

Amman

88

-100%

-50%

0%

50%

100%

150%

200%

250%

-35% -30% -25% -20% -15% -10% -5% 0% 5% 10% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
TABLE B6

SUMMARY OF CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN SAN FRANCISCO AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional.

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Bookings Share of Bookings

Percentage

Difference Point

Cabin City 2009 2014 Count Percent 2009 2014 Difference

[a] [b] [c] [d] [e] = [d]-[c] [f] = [e]/[c] [g] [h] [i] = [h]-[g]

Economy Delhi 34,118 78,220 44,102 129.3% 32.7% 57.3% 24.6%

Economy Mumbai 28,757 32,745 3,989 13.9% 46.3% 49.0% 2.7%

Economy Bangalore 10,259 18,589 8,330 81.2% 24.1% 27.9% 3.9%

Economy Tehran 12,813 10,988 -1,825 -14.2% 69.1% 47.1% -22.1%

Economy Amman 6,100 7,982 1,883 30.9% 91.6% 95.9% 4.3%

Economy Beirut 3,621 6,046 2,426 67.0% 85.3% 97.5% 12.2%

Economy Hyderabad 8,683 5,751 -2,932 -33.8% 25.7% 12.6% -13.1%

Economy Chennai 3,203 5,703 2,501 78.1% 8.6% 14.2% 5.5%

Economy Dubai 3,647 3,686 39 1.1% 17.0% 8.3% -8.7%

Economy Riyadh 996 2,109 1,113 111.7% 73.6% 66.9% -6.6%

Premium Delhi 2,297 3,373 1,077 46.9% 58.9% 40.6% -18.3%

Premium Bangalore 2,151 2,766 616 28.6% 53.2% 33.6% -19.6%

Premium Mumbai 1,910 2,374 464 24.3% 49.8% 35.2% -14.7%

Premium Riyadh 265 763 499 188.5% 69.8% 71.5% 1.7%

Premium Dubai 509 724 215 42.2% 11.2% 7.8% -3.4%

Premium Beirut 346 676 330 95.4% 96.8% 99.1% 2.3%

Premium Chennai 565 599 35 6.1% 36.9% 19.7% -17.2%

Premium Tehran 582 539 -43 -7.4% 75.1% 50.0% -25.1%

Premium Hyderabad 797 455 -342 -42.9% 47.2% 17.8% -29.4%

Premium Amman 275 362 88 31.9% 92.1% 93.1% 0.9%
FIGURE B11

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN WASHINGTON D.C. AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

ECONOMY CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Beirut

5,357

Amman

3,549 Mumbai

839

Kuwait

-53,672

Doha

-4,411

Delhi

-1,315

Bangalore

-1,313

Dubai

-1,015 Chennai

-584

Bahrain

14,251

-150%

-100%

-50%

0%

50%

100%

150%

200%

250%

-60% -50% -40% -30% -20% -10% 0% 10% 20% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
FIGURE B12

CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN WASHINGTON D.C. AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

PREMIUM CLASS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional. The value under each destination represents the differences in annual traffic 

volumes between 2009 and 2014 (negative values indicate a decline in volume).

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Riyadh

623

Dubai

330

Bangalore

97

Beirut

64

Kuwait

-3,734

Doha

-1,629

Delhi

-684

Amman

-549

Mumbai

-80

Bahrain

1,314

-80%

-60%

-40%

-20%

0%

20%

40%

60%

80%

100%

120%

-50% -40% -30% -20% -10% 0% 10% 20% Percentage Change in Volume of Travel Carried

Percentage Point Change in Share of Travel Volume

Lost Share & Gained Bookings Lost Share & Lost Bookings Gained Share & Gained Bookings Gained Share & Lost Bookings
TABLE B7

SUMMARY OF CHANGES IN IMMUNIZED CARRIERS’ SHARE AND VOLUME OF TRAVEL

BETWEEN WASHINGTON D.C. AND KEY INDIAN SUB-CONTINENT/MIDDLE EASTERN DESTINATIONS

2009 – 2014

Notes: 

1 Immunized alliances are defined in accordance with the U.S. Department of Transportation Compendium of 

Antitrust Immunity Cases.

2 This analysis compares travel volumes between March 2014 and February 2015 to the travel volumes between 

March 2009 and February 2010.

3 Traffic flows are non-directional.

Sources: 

MIDT; U.S. Department of Transportation Compendium of Antitrust Immunity Cases Pursuant to 49 U.S.C §§ 

41308-42309 (July 2014).

Bookings Share of Bookings

Percentage

Difference Point

Cabin City 2009 2014 Count Percent 2009 2014 Difference

[a] [b] [c] [d] [e] = [d]-[c] [f] = [e]/[c] [g] [h] [i] = [h]-[g]

Economy Dubai 55,033 54,018 -1,015 -1.8% 91.6% 59.3% -32.4%

Economy Kuwait 77,172 23,500 -53,672 -69.5% 95.8% 80.6% -15.2%

Economy Bahrain 8,593 22,844 14,251 165.8% 87.8% 93.7% 5.8%

Economy Delhi 23,869 22,554 -1,315 -5.5% 69.2% 44.3% -24.9%

Economy Beirut 11,609 16,965 5,357 46.1% 98.4% 88.9% -9.5%

Economy Amman 11,932 15,481 3,549 29.7% 99.6% 86.0% -13.6%

Economy Mumbai 14,581 15,420 839 5.8% 65.2% 42.1% -23.0%

Economy Doha 16,033 11,622 -4,411 -27.5% 54.8% 38.1% -16.7%

Economy Bangalore 10,925 9,612 -1,313 -12.0% 94.8% 44.2% -50.6%

Economy Chennai 8,383 7,799 -584 -7.0% 51.0% 28.4% -22.7%

Premium Dubai 13,395 13,725 330 2.5% 92.0% 55.9% -36.1%

Premium Delhi 5,026 4,342 -684 -13.6% 83.0% 58.5% -24.5%

Premium Kuwait 7,417 3,683 -3,734 -50.3% 97.4% 76.0% -21.4%

Premium Amman 3,628 3,079 -549 -15.1% 99.8% 93.2% -6.5%

Premium Riyadh 2,136 2,759 623 29.2% 45.5% 28.5% -17.0%

Premium Bahrain 1,400 2,713 1,314 93.9% 73.8% 80.6% 6.8%

Premium Beirut 2,111 2,174 64 3.0% 99.7% 95.2% -4.5%

Premium Mumbai 2,073 1,993 -80 -3.8% 80.4% 48.1% -32.3%

Premium Doha 3,457 1,828 -1,629 -47.1% 44.4% 22.9% -21.5%

Premium Bangalore 1,723 1,820 97 5.6% 98.0% 60.4% -37.5%
APPENDIX C
FIGURE C1

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON CHICAGO TO HYDERABAD ROUTE

APRIL 2013 – MARCH 2015

Notes:

1 Immunized Alliance Members in this chart indicates the range of fares published by American, British Airways, 

and Lufthansa. Etihad's fare was on average $17 (or 1%) less than the median offered by these carriers.

2 Non-Immunized Carriers in this chart indicated the range of fares published by Emirates, Qatar Airways, and Air 

India. Etihad's fare was on average $31 (or 2%) less than the median offered by these carriers.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
FIGURE C2

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON NEW YORK CITY TO MUMBAI ROUTE

APRIL 2013 – MARCH 2015

Notes:

1 Immunized Alliance Members in this chart indicates the range of fares published by Delta, American, United, 

British Airways and Lufthansa. Etihad's fare was on average $136 (or 7%) less than the median offered by these 

carriers.

2 Non-Immunized Carriers in this chart indicated the range of fares published by Emirates, Qatar Airways, Air 

India, and Turkish Airways. Etihad's fare was on average $189 (or 11%) more than the median offered by these 

carriers.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
FIGURE C3

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON NEW YORK CITY TO HYDERABAD ROUTE

APRIL 2013 – MARCH 2015

Notes:

1 Immunized Alliance Members in this chart indicates the range of fares published by American, United, British 

Airways, and Lufthansa. Etihad's fare was on average $99 (or 5%) more than the median offered by these 

carriers.

2 Non-Immunized Carriers in this chart indicated the range of fares published by Emirates, Qatar Airways, and Air 

India. Etihad's fare was on average $140 (or 7%) more than the median offered by these carriers.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis. 

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
FIGURE C4

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON NEW YORK CITY TO ISLAMABAD ROUTE

APRIL 2013 – MARCH 2015

Notes:

1 Immunized Alliance Members in this chart indicates the range of fares published by American and United.

Etihad's fare was on average $139 (or 7%) less than the median offered by these carriers.

2 Non-Immunized Carriers in this chart indicated the range of fares published by Emirates, Qatar Airways, and 

Turkish Airways. Etihad's fare was on average $52 (or 3%) more than the median offered by these carriers.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
FIGURE C5

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON NEW YORK CITY TO DHAKA ROUTE

APRIL 2013 – MARCH 2015

Notes:

1 Non-Immunized Carriers in this chart indicated the range of fares published by Emirates, Qatar Airways and 

Turkish Airways. Etihad's fare was on average $100 (or 5%) more than the median offered by these carriers.

2 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis. 

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
FIGURE C6

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON NEW YORK CITY TO COLOMBO

APRIL 2013 – MARCH 2015

Notes:

1 Immunized Alliance Members in this chart indicates the range of fares published by American and United. 

Etihad's fare was on average $228 (or 11%) less than the median offered by these carriers.

2 Non-Immunized Carriers in this chart indicated the range of fares published by Air India, Emirates, and Qatar 

Airways. Etihad's fare was on average $4 (or 0%) more than the median offered by these carriers.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
FIGURE C7

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON SAN FRANCISCO TO DELHI ROUTE

APRIL 2013 – MARCH 2015

Notes:

1 Immunized Alliance Members in this chart indicates the range of fares published by Delta, American, United, 

British Airways, KLM, and Lufthansa. Etihad's fare was on average $82 (or 5%) less than the median offered by 

these carriers.

2 Non-Immunized Carriers in this chart indicated the range of fares published by Emirates and Air India. Etihad's 

fare was on average $161 (or 9%) less than the median offered by these carriers.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
FIGURE C8

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON SAN FRANCISCO TO MUMBAI ROUTE

APRIL 2013 – MARCH 2015

Notes:

1 Immunized Alliance Members in this chart indicates the range of fares published by Delta, United, British 

Airways, KLM, and Lufthansa. Etihad's fare was on average $154 (or 8%) less than the median offered by these 

carriers.

2 Non-Immunized Carriers in this chart indicated the range of fares published by Emirates and Air India. Etihad's 

fare was on average $186 (or 10%) less than the median offered by these carriers.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
FIGURE C9

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON LOS ANGELES TO COLOMBO

APRIL 2013 – MARCH 2015

Notes:

1 Non-Immunized Carriers in this chart indicated the range of fares published by Emirates and Turkish Airways. 

Etihad's fare was on average $197 (or 13%) higher than the median offered by these carriers.

2 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
FIGURE C10

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON WASHINGTON D.C TO ISLAMABAD ROUTE

APRIL 2013 – MARCH 2015

Notes:

1 Immunized Alliance Members in this chart indicates the range of fares published by American and United. 

Etihad's fare was on average $393 (or 19%) less than the median offered by these carriers.

2 Non-Immunized Carriers in this chart indicated the range of fares published by Qatar Airways and Turkish 

Airways. Etihad's fare was on average $47 (or 3%) less than the median offered by these carriers.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
FIGURE C11

ANALYSIS OF MEDIAN PUBLISHED ECONOMY CLASS FARES 

ON WASHINGTON D.C. TO DHAKA ROUTE

APRIL 2013 – MARCH 2015

Notes:

1 Immunized Alliance Members in this chart indicates the range of fares published by American and United.

Etihad's fare was on average $704 (or 26%) less than the median offered by these carriers.

2 Non-Immunized Carriers in this chart indicated the range of fares published by Emirates, Qatar Airways, and 

Turkish Airways. Etihad's fare was on average $159 (or 9%) more than the median offered by these carriers.

3 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

Premium Economy fares are not included in the analysis.

Sources: 

ATPCO and GDS pricing data; Canadian Foreign Exchange Services.
APPENDIX D
FIGURE D1

ETIHAD REVENUE PER KILOMETER ON CHICAGO TO HYDERABAD ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM CHICAGO TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: Air France, American, British Airways, Delta, KLM, Lufthansa, and United.

 Benchmark includes fares published by carriers on the following routes: CHI-FRA, CHI-LON, CHI-PAR.

3 There are 7 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 80% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com.
FIGURE D2

ETIHAD REVENUE PER KILOMETER ON NEW YORK TO MUMBAI ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM NEW YORK TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: Air France, American, British Airways, Delta, KLM, Lufthansa, and United.

 Benchmark includes fares published by carriers on the following routes: NYC-FRA, NYC-LON, NYC-PAR.

3 There are 7 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 88% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com.
FIGURE D3

ETIHAD REVENUE PER KILOMETER ON NEW YORK TO COLOMBO ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM NEW YORK TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: Air France, American, British Airways, Delta, KLM, Lufthansa, and United.

 Benchmark includes fares published by carriers on the following routes: NYC-FRA, NYC-LON, NYC-PAR.

3 There are 7 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 108% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com.
FIGURE D4

ETIHAD REVENUE PER KILOMETER ON NEW YORK TO DHAKA ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM NEW YORK TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: Air France, American, British Airways, Delta, KLM, Lufthansa, and United.

 Benchmark includes fares published by carriers on the following routes: NYC-FRA, NYC-LON, NYC-PAR.

3 There are 7 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 94% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com.
FIGURE D5

ETIHAD REVENUE PER KILOMETER ON NEW YORK TO HYDERABAD ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM NEW YORK TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: Air France, American, British Airways, Delta, KLM, Lufthansa, and United.

 Benchmark includes fares published by carriers on the following routes: NYC-FRA, NYC-LON, NYC-PAR.

3 There are 7 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 87% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com.
FIGURE D6

ETIHAD REVENUE PER KILOMETER ON NEW YORK TO ISLAMABAD ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM NEW YORK TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: Air France, American, British Airways, Delta, KLM, Lufthansa, and United.

 Benchmark includes fares published by carriers on the following routes: NYC-FRA, NYC-LON, NYC-PAR.

3 There are 7 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 69% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com.
FIGURE D7

ETIHAD REVENUE PER KILOMETER ON WASHINGTON D.C. TO DHAKA ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM WASHINGTON D.C. TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: American, British Airways, Lufthansa, and United.

 Benchmark includes fares published by carriers on the following routes: WAS-FRA, WAS-LON.

3 There are 4 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 82% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com
FIGURE D8

ETIHAD REVENUE PER KILOMETER ON WASHINGTON D.C. TO ISLAMABAD ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM WASHINGTON D.C. TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: American, British Airways, Lufthansa, and United.

Benchmark includes fares published by carriers on the following routes: WAS-FRA, WAS-LON.

3 There are 4 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 85% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com.
FIGURE D9

ETIHAD REVENUE PER KILOMETER ON LOS ANGELES TO COLOMBO ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM ATLANTA OR DALLAS TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: Air France, American, British Airways, Delta, and KLM.

 Benchmark includes fares published by carriers on the following routes: ATL-AMS, ATL-PAR, DFW-LON.

3 There are 8 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 120% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com.
FIGURE D10

ETIHAD REVENUE PER KILOMETER ON SAN FRANCISCO TO MUMBAI ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM ATLANTA OR DALLAS TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: Air France, American, British Airways, Delta, and KLM. 

Benchmark includes fares published by carriers on the following routes: ATL-AMS, ATL-PAR, DFW-LON.

3 There are 8 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 91% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com.
FIGURE D11

ETIHAD REVENUE PER KILOMETER ON SAN FRANCISCO TO DELHI ROUTE

COMPARED TO IMMUNIZED ALLIANCE MEMBERS’ REVENUES PER KILOMETER

FROM ATLANTA OR DALLAS TO KEY IMMUNIZED EUROPEAN DESTINATIONS

APRIL 2013 – MARCH 2015

Notes:

1 ATPCO data only contain base fares, which are supplemented by data on taxes and fees from GDS (for each 

carrier and route combination) in order to calculate all-in fares. All fares have been converted to US dollars.

The analysis uses each carrier's median published round trip economy fare for a given route and month. 

Premium Economy fares are not included in the analysis.

2 Benchmark includes Immunized Alliance members as per the U.S. DOT Compendium of Antitrust Immunity 

Cases: Air France, American, British Airways, Delta, and KLM. 

 Benchmark includes fares published by carriers on the following routes: ATL-AMS, ATL-PAR, DFW-LON.

3 There are 8 distinct benchmark carrier-route pairings.

4 On average, the median benchmark fare per-kilometer is 75% higher than Etihad’s median fare.

Sources: 

ATPCO and GDS pricing data; www.gcmap.com.