BEFORE THE 


DEPARTMENT OF TRANSPORTATION 


WASHINGTON, D.C. 


Joint Application of 

AMERICAN AIRLINES, INC. 

and DOT-OST-2010 

JAPAN AIRLINES INTERNATIONAL CO., LTD. 

under 49 U.S.C. §§ 41308 and 41309 for 

approval of and antitrust immunity for 

alliance agreements 

[PUBLIC] JOINT APPLICATION FOR ANTITRUST IMMUNITY 

Communi cat with respect to this document should be sent to: 

For American Airlines: 

TSUTOMU ANDO VlRASB VAHIDI 

Executive Officer - Senior Vice President ­

International Affairs Planning 

Japan Airlines American Airlines, Inc. 

International Co., Ltd. P.O. Box 619616, MD 5634 

4-11, Higashi shinagawa DFW Airport, Texas 75161 

2-chome, ku 

Tokyo 140-8637, Japan KENJI C. HASHIMOTO 

Vice President ­

TORU MIZUNO Strategic Alliances 

Vice President - American Airlines, Inc. 

International Affairs P.O. Box 619616, MD 5635 

Japan Airlines DFW Airport, Texas 75261 

International Co., Ltd. 

4-11, Higashi-shinagawa WILLIAM K. RIS, JR. 

2-chome, Shinagawa-ku Senior Vice President ­

Tokyo 140-8637, Japan Government Affairs 

American Airlines, Inc. 

YUKI SAITO 1101 1 Street, N.W. 

Director, Government Affairs Washington, D.C. 20036 

Japan Airlines 

International Co., Ltd. 

1330 Connecticut Ave., N.W. 

Washington, D.C. 20036 
WILLIAM KARAS 

CAROL GOSAIN 

& Johnson LLP 

1330 Connecticut Ave., N.W. 

Washington, D.C. 20036 

(202) 429-6223 

wkaras@steptoe.com 

cgosain@steptoe.com 

February 12, 2010 

ROBERT A. WIRICK 

Director, Regulatory 

American Airlines, Inc. 

P.O. Box 619616, MD 5635 

DFW Airport, Texas 75261 

(817) 963-0394 

robert.wirick@aa.com 

W. BRUCE WARK 

As General Counsel 

JEFFREY A. OGAR 

Senior Attorney 

American Airlines, Inc. 

P.O. Box 619616, MD 5675 

DFW Airport, Texas 75261 

(817) 967 3458 

jeff. .com 

CARL B. NELSON, JR. 


As General Counsel 


American Airlines, Inc. 


1101 1 Street, N.W. 


Washington, D.C. 20036 


(202) 496-5647 

carl.nelson@aa.com 
TABLE OF CONTENTS

INTRODUCTION ...................................................... 2 

I. THE JOINT APPLICATION IS AN ESSENTIAL PART OF THE 

U.S.-JAPAN OPEN SKIES AGREEMENT, AND ITS APPROVAL 

WILL ENSURE THAT CONSUMERS ENJOY THE MAXIMUM 

BENEFITS OF TRANSPACIFIC LIBERALIZATION ..................... 3 

A. U.S.-Japan Open Skies Will Facilitate 

Enhanced Interalliance Competition ..................... 4 

B. U.S.-Japan Open Skies Will Ensure Competitive 

Access To Tokyo Gateway Airports ........................... 5 

II. THE JOINT APPLICANTS HAVE PROPOSED AN ALLIANCE THAT 

EASILY MEETS THE DEPARTMENT’S STANDARD OF REVIEW ................ 6 

A. The Joint Applicants Have Executed Alliance 

Agreements That Will Allow oneworld To 

Achieve Network Integration Comparable 

To Both Star and SkyTeam ................................ 7 

1. The JBA Will Create Metal Neutrality 

Between American And JAL ........................... 7 

2. The Joint Applicants Plan Extensive 

Coordination Once The Proposed Alliance 

Is Approved And Immunized ........................... 10 

3. The Proposed Alliance Is Integral To 

oneworld’s Future ................................ 11 

B. The Alliance Agreements Meet The Department’s 

Standard Of Review For Antitrust 

Immunity Applications ...................................... 12 

II. THE PROPOSED ALLIANCE WILL CREATE SIGNIFICANT 

CONSUMER BENEFITS BY EXPANDING AND INTEGRATING 

THE ONEWORLD NETWORK, AND WILL MAXIMIZE THE 

BENEFITS OF U.S.-JAPAN OPEN SKIES ........................... 13 

A. The Full Benefits Of U.S.-Japan Open Skies 

Will Not Be Realized Absent Strong 

Transpacific Interalliance Competition Among 

Star, SkyTeam And oneworld ................................ 13 

1. The Department Has Recognized That 

Interalliance Competition Is Necessary 

For Consumers To Receive The Maximum 

Benefits From Open Skies ........................... 13 
- ii –

2. Allowing oneworld To Operate As An 

Integrated Joint Venture Will Drive 

All Three Globally Branded Alliances 

To Deliver Maximum Consumer Benefits ................ 14 

B. The Proposed Alliance Will Create Significant 

New Consumer Benefits ...................................... 15 

1. The Metal Neutrality Created By The JBA 

Is Essential To Facilitating An Integrated 

Transpacific oneworld Network ..................... 16 

2. The Proposed Alliance Will Create Expanded 

And Enhanced Route And Schedule Options .......... 17 

 a. New Transpacific Routes And Service .......... 18 

 b. New Behind/Beyond Connectivity ................ 20 

 i. New And Improved Connections .......... 20 

 ii. Competition With Star/SkyTeam .......... 20 

 3. Corporate Accounts ................................ 21 

4. Combinable Fares ...................................... 22 

 5. Joint Procurement ................................ 23 

III. U.S.-JAPAN OPEN SKIES WILL ENSURE THAT THE PROPOSED 

ALLIANCE WILL NOT SIGNIFICANTLY REDUCE COMPETITION .......... 24 

A. The Proposed Alliance Will Enhance Global 

And Transpacific Network Competition By 

Facilitating U.S.-Japan Open Skies ..................... 25 

B. The Proposed Alliance Will Not Significantly 

Reduce Competition In Any Global, Regional 

Or Country-Pair Market ................................ 25 

1. Global And Transpacific Interalliance 

Competition ...................................... 25 

 a. Global ...................................... 25 

 b. Transpacific ................................ 26 

 2. U.S.-Japan Competition ........................... 27 
- iii –

C. City-Pair Competition ...................................... 28 

1. New York-Tokyo ...................................... 28 

 2. Los Angeles-Tokyo ................................ 29 

 3. Chicago-Tokyo ...................................... 29 

IV. THE JOINT APPLICANTS WILL NOT PROCEED WITH THE 

PROPOSED ALLIANCE ABSENT ANTITRUST IMMUNITY ..................... 30 

V. OTHER APPROVAL ISSUES, CONDITIONS AND INFORMATION ................ 31 

A. Document Production And Responses 

To Interrogatories ...................................... 31 

B. Transpacific Routes ...................................... 32 

C. Transpacific Carriers Within The 

Three Alliances ........................................... 32 

D. Codeshare Agreements ...................................... 32 

E. Relationship To oneworld ................................ 32 

F. Hub Airports ........................................... 33 

G. Significant Service And 

Equipment Changes ...................................... 34 

H. Competitive Access To Non-U.S. 

Gateway Airports ........................................... 34 

I. Impact On Revenue ...................................... 34 

J. Labor Issues ........................................... 34 

K. Computer Reservations Systems ........................... 34 

L. Civil Reserve Air Fleet ................................ 35 

M. CRS Booking Data ........................................... 35 

N. Resubmission Of Alliance Agreements ..................... 35 

O. Conditions ................................................. 35 

CONCLUSION ........................................................... 36 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

-------------------------------------------------- 

Joint Application of : 

 : 

 AMERICAN AIRLINES, INC. : 

 : 

 and : 

 : DOT-OST-2010-______ 

 JAPAN AIRLINES INTERNATIONAL CO., LTD. : 

 : 

under 49 U.S.C. §§ 41308 and 41309 for : 

approval of and antitrust immunity for : 

alliance agreements. : 

-------------------------------------------------- 

[PUBLIC] JOINT APPLICATION FOR ANTITRUST IMMUNITY 

American Airlines, Inc. (along with its affiliates American Eagle 

Airlines, Inc. and Executive Airlines, Inc. d/b/a American Eagle) and Japan 

Airlines International Co., Ltd. (along with its affiliates Hokkaido Air 

System Co., Ltd., J-Air Co., Ltd., JAL Express Co., Ltd., JALways Co., Ltd., 

Japan Air Commuter Co., Ltd., Japan TransOceanAir Co., Ltd. and Ryukyu Air 

Commuter Co., Ltd.) jointly apply under 49 U.S.C. §§ 41308 and 41309 for 

approval of and antitrust immunity for a bilateral alliance agreement 

(Exhibit JA-1) and a metal neutral Joint Business Agreement (“JBA”, Exhibit 

JA-2), as well as existing and future agreements implementing the 

transactions and arrangements contemplated by the bilateral alliance 

agreement and JBA. 

 
- 2 –

PUBLIC VERSION 

This proposed alliance will create metal neutrality between two of 

oneworld’s core transpacific members – American and JAL. These agreements 

will provide for revenue sharing and closer integration, giving oneworld the 

ability to offer consumers an effective competitive alternative to Star and 

SkyTeam in Asia, and will maximize the benefits that the U.S.-Japan Open 

Skies Agreement will make possible. American and JAL will implement their 

bilateral alliance agreement immediately upon approval, and will implement 

the JBA within 18 months of the Department’s final order granting antitrust 

immunity consistent with the precedent set in SkyTeam II (Order 2008-4-17, 

p. 20). 

INTRODUCTION 

On December 11, 2009, the U.S. and Japan initialed a Memorandum of 

Understanding that will eliminate longstanding restrictions on competition 

between the U.S. and Japan by bringing into force a landmark Open Skies 

agreement. The Joint Applicants applaud the U.S. government for this 

achievement, as opening the largest Asian gateway for U.S. traffic will 

improve competition on routes to Japan and beyond. Not only will U.S.-Japan 

Open Skies work as a catalyst for liberalizing other restrictive bilateral 

agreements, but the ability to form integrated networks between U.S. and 

Japanese hub airports will create an improved product for all consumers 

flying between North America and Asia. 

 
- 3 –

PUBLIC VERSION 

Relying on this historic agreement, the Joint Applicants have entered 

into a bilateral alliance agreement and an integrated metal-neutral joint 

venture that will help generate the consumer benefits that Open Skies makes 

possible. This proposed alliance will deliver significant consumer 

benefits, and creates no risk of harm to competition in any relevant market. 

Moreover, prompt approval and antitrust immunity to implement the bilateral 

alliance agreement and the JBA are imperative to ensure the implementation 

of the U.S.-Japan Open Skies Agreement. Accordingly, the Joint Applicants 

apply pursuant to 49 U.S.C. §§ 41308 and 41309 for approval and global 

antitrust immunity that will permit consumers to enjoy the full benefits of 

Open Skies. 

I. THE JOINT APPLICATION IS AN ESSENTIAL PART OF THE U.S.-JAPAN OPEN 

SKIES AGREEMENT, AND ITS APPROVAL WILL ENSURE THAT CONSUMERS ENJOY THE 

MAXIMUM BENEFITS OF TRANSPACIFIC LIBERALIZATION 

The Joint Application is predicated upon the long-sought U.S.-Japan 

Open Skies Agreement that will liberalize air transportation between the two 

countries, freeing consumers from restraints on competition that have 

existed for more than a half century. The Joint Applicants were vigorous 

advocates for liberalization, which will allow oneworld to compete more 

effectively with Star and SkyTeam for transpacific traffic. U.S.-Japan Open 

Skies will remove limits on the number of carriers operating flights between 

the two countries, remove restrictions on capacity and pricing, and allow 

unlimited opportunities for cooperative marketing agreements between U.S. 

and Japanese carriers. 

 
- 4 –

PUBLIC VERSION 

Prompt approval of this Joint Application will ensure that the U.S.-

Japan Open Skies Agreement becomes effective, enabling consumers to enjoy 

the benefits of liberalization at the earliest possible date. Conversely, 

any delay in approval could jeopardize implementation, as network 

integration between U.S. and Japanese carriers was expressly contemplated 

during the intergovernmental negotiations last year, and approval of this 

application will facilitate the implementation of U.S.-Japan Open Skies.1

A. U.S.-Japan Open Skies Will Facilitate Enhanced Interalliance 

Competition 

The U.S.-Japan Open Skies Agreement contains all of the elements 

typically required for full liberalization. It establishes a framework for 

significantly expanded transpacific competition by enabling carriers from 

both countries to introduce new U.S.-Japan service – including the 

restoration of scheduled service between the U.S. and Tokyo’s Haneda 

Airport. With capacity increases at Narita Airport planned for March 2010 

upon the opening of the Runway B extension, and the planned opening of 

Haneda to scheduled transpacific flights in October 2010, the new agreement 

is well-timed to enable U.S. carriers to take advantage of new capacity at 

these airports. 

 

                                                           

1

 A number of open skies agreements with other countries were conditioned on 

a grant of antitrust immunity to the countries’ flag carriers, including the 

open skies agreements with the Netherlands, Chile, Germany, France, Canada 

and Italy. 
- 5 –

PUBLIC VERSION 

The American/JAL relationship is particularly vital to enhancing 

interalliance competition across the Pacific. SkyTeam has an extremely 

strong position, with Delta’s own-metal connecting hub at Narita, as well as 

the immunized Delta/Korean alliance with a hub at Seoul. Star is similarly 

strong, with United’s own-metal Narita hub and the immunized United/Asiana 

alliance, also with a hub at Seoul. In addition, United is seeking 

antitrust immunity with Continental and All Nippon Airways (DOT-OST-2009-

0350). In contrast, oneworld has no U.S. carrier connecting hub at Narita, 

and no immunized alliance in Asia. Thus, the proposed American/JAL alliance 

is critically important to enhancing competition among the three alliances. 

B. U.S.-Japan Open Skies Will Ensure Competitive Access To Tokyo 

Gateway Airports 

The U.S.-Japan Open Skies Agreement will create opportunities for U.S. 

carriers that do not currently serve Tokyo to launch new service, as well as 

opportunities for incumbents to expand their existing operations. Open 

Skies will also allow new service between the U.S. and Haneda, adding new 

choices for consumers and opportunities to maximize hub connectivity. In 

addition, the slot pools at Narita and Haneda will expand substantially 

beginning in 2010, creating an unprecedented opportunity for carriers to 

obtain access at both airports. Slot allocation will be administered in 

accordance with IATA guidelines, ensuring that consumers benefit from both 

growth and increased competition. 

 
- 6 –

PUBLIC VERSION 

II. THE JOINT APPLICANTS HAVE PROPOSED AN ALLIANCE THAT EASILY MEETS THE 

DEPARTMENT’S STANDARD OF REVIEW 

The JBA is at the heart of the proposed alliance between American and 

JAL. The JBA will create a metal neutral joint venture for oneworld’s 

transpacific network. It is anticipated that the JBA will be expanded to 

other oneworld members and other geographic regions as the alliance’s 

integration deepens and matures. The JBA will create stronger interalliance 

competition in Asia among Star, SkyTeam (both of which already operate 

immunized hubs in Seoul) and oneworld. As the Department noted in SkyTeam 

II (DOT-OST-2007-28644), such joint ventures are “likely to result in the 

introduction of new capacity and greater availability of discount fares 

across the entire joint network – benefits that we tentatively find to be 

substantial” (Order 2008-4-17, p. 15). 

The JBA will operate alongside a bilateral alliance agreement between 

American and JAL. The Joint Applicants plan to use their antitrust immunity 

to achieve efficiencies that make their products more attractive to 

consumers and more competitive in the marketplace. Thus, the proposed 

alliance meets the statutory standards for granting antitrust immunity – it 

is necessary “to achieve important public benefits” and it does not 

“substantially reduce[] or eliminate[] competition” (49 U.S.C. § 41309(b)).

 
- 7 –

PUBLIC VERSION 

A. The Joint Applicants Have Executed Alliance Agreements That Will 

Allow oneworld To Achieve Network Integration Comparable To Both 

Star and SkyTeam 

1. The JBA Will Create Metal Neutrality Between American And 

JAL 

The Joint Applicants seek approval for a highly-integrated, revenuesharing joint venture that will strengthen their alliance by eliminating 

each carrier’s economic incentive to maximize its own revenue. Only the 

closer cooperation made possible through a joint venture based on metal 

neutrality – or indifference as to which airline actually carries a customer 

– will maximize the consumer benefits that immunized alliances make 

possible. This is because metal neutrality removes each carrier’s incentive 

to act opportunistically in ways that inure to its own short-term financial 

advantage, to the detriment of the efficiencies and consumer benefits that 

could otherwise be delivered by the alliance. 

Accordingly, the Joint Applicants are seeking approval for a highly 

integrated joint venture with revenue sharing that creates metal neutrality. 

By providing for the broad sharing of revenue on a metal neutral foundation, 

the JBA will ensure that American and JAL act for the benefit of – and are 

compensated for their contribution to – the alliance as a whole. While the 

details of the joint ventures in Star and SkyTeam in prior dockets were 

subject to confidential treatment, the Department publicly described the 

joint venture approved in SkyTeam II as follows: 

 
- 8 –

PUBLIC VERSION 

“At its core, the proposed alliance features a joint 

venture between Delta, Northwest, Air France, and KLM 

(the ‘4-way JV’). Upon implementation, the 4-way JV 

will bring all transatlantic services offered by the 

venture participants under the control of the venture. 

Committees and working groups, composed of senior 

representatives from each airline, will jointly plan 

and manage capacity, pricing, and financial 

settlement. The 4-way JV attempts to align the 

economic incentives of the participants to create what 

is known in the airline industry as ‘metal 

neutrality.’ Instead of competing among themselves for 

a greater share of revenue by trying to carry 

passengers on their own metal (aircraft), the 

participants agree to pool revenues and costs so that 

they become indifferent as to which carrier operates 

the service. Much like a single firm, the 4-way JV 

establishes a common bottom line where, according to 

the Joint Applicants, each participant shares the same 

incentive to maximize the profits of the venture” 

(Order 2008-4-17, p. 3). 

The JBA here contains the following key provisions, which are central 

to the American/JAL proposal:2

 Governance (Article 4): [REDACTED]

 Geographic Scope (Section 2.4): [REDACTED]

 

                                                           

2

 A grant of immunity here is consistent with the precedent set in SkyTeam 

II, in which the Department approved the proposed alliance despite the fact 

that “[t]he 4-way JV is not yet ready for implementation. The participants 

have yet to agree upon how to value each carrier’s contribution to the 

venture, which has implications for how profits and losses are divided” 

(Order 2008-4-17, p. 3). The Joint Applicants are prepared to accept the 

same condition imposed in SkyTeam II, terminating antitrust immunity unless 

the JBA is implemented within 18 months of final approval (Id. at 20). 
- 9 –

PUBLIC VERSION 

 Revenue Sharing (Article 7/Schedule 1): [REDACTED]

 Revenue Management/Capacity Planning (Sections 3.3/5.6/5.7): 

[REDACTED] 

 Sales/Marketing (Article 5): [REDACTED]

 Frequent Flyer Programs (Section 6): [REDACTED]

 Cost Synergies (Section 3.9): [REDACTED]

In addition to the JBA, American and JAL have executed a bilateral 

alliance agreement that mirrors those approved and immunized in other 

dockets, such as SkyTeam II and Star.

 
- 10 –

PUBLIC VERSION 

2. The Joint Applicants Plan Extensive Coordination Once The 

Proposed Alliance Is Approved And Immunized 

Approval and immunization of the American/JAL alliance agreements will 

enable close integration of the two carriers’ activities – which will make 

oneworld a far stronger competitor against the integrated Star and SkyTeam 

hubs in Tokyo and Seoul. This coordination will include the following: 

 Codesharing: Each Applicant will codeshare on the services operated 

by the other to the greatest extent possible. American and JAL are 

separately filing for blanket codeshare approvals under the Open 

Skies agreement (DOT-OST-1999-4994). 

 Pricing: The Joint Applicants will cooperate in establishing fares, 

rates and pricing strategies for services provided under their 

alliance agreements and JBA. 

 Yield Management: The Joint Applicants will cooperate on inventory 

control and yield management as those functions relate to services 

provided under the alliance agreements. The Joint Applicants will 

provide each other with access to their respective yield management 

systems, and will consult closely in the yield management process. 

 Schedules: The Joint Applicants will jointly plan their respective 

schedules and related connecting services in order to maximize and 

optimize feasible routings and service options available to 

consumers, and to minimize connecting times for the benefit of 

consumers. 

 Marketing And Product Offering: The Joint Applicants will jointly 

market, promote and advertise the services covered by the alliance 

agreements. They will also seek to harmonize their respective 

service standards and jointly develop new products where 

appropriate. The carriers may seek to use an alliance mark or brand 

to represent their alliance and to link their frequent flyer 

programs. 

 Frequent Flyer Programs: The Joint Applicants will offer reciprocal 

frequent flyer programs to allow members of one carrier’s frequent 

flyer program to accrue mileage and redeem awards on the services of 

the other. 

 Sales: The Joint Applicants will jointly determine the most 

efficient strategies for selling alliance services, coordinating 

their sales forces, and allocating their sales resources. 

 Airports: The Joint Applicants will determine how to most 

efficiently utilize their facilities at the common airports they 

serve. 
- 11 –

PUBLIC VERSION 

 Cost Reduction: The Joint Applicants will coordinate their efforts 

to reduce costs in a variety of areas, including but not limited to 

fuel purchasing, aircraft acquisition, and design and purchase of 

replacement parts. 

This extensive cooperation will allow the Joint Applicants to generate 

significant efficiencies and to provide an improved range of enhanced and 

more competitive online services and products to oneworld passengers. The 

benefits and efficiencies of this alliance could not be achieved absent 

antitrust immunity. 

3. The Proposed Alliance Is Integral To oneworld’s Future 

The proposed alliance will allow oneworld to enhance its product 

offerings in ways previously available only to Star and SkyTeam. For 

example, unlike Delta and United (which each operate hubs at Narita), 

American’s only current access to behind/beyond Tokyo feeder routes is 

through non-immunized codesharing with JAL. Once the proposed alliance is 

immunized, this competitive imbalance will be remedied and customers will 

have more choices, such as corporate customers being able to choose from 

integrated network alliance contracts with any one of the three major global 

alliances.

 
- 12 –

PUBLIC VERSION 

B. The Alliance Agreements Meet The Department’s Standard Of Review 

For Antitrust Immunity Applications 

The Department has a two-step review process for international 

aviation alliance agreements (Order 2008-4-17, p. 4). First, the alliance 

must be approved under 49 U.S.C. § 41309, which requires a showing that the 

agreements “are not adverse to the public interest and do not violate the 

statute” (Id.). This “requires consideration of, among other things, 

international comity and foreign policy factors” (Id., p. 5). Any party 

opposing the application “has the burden of proving that it substantially 

reduces or eliminates competition and that less anticompetitive measures are 

available” (Id.). Once the agreements are approved, the Department has the 

“authority to exempt airlines from the antitrust laws to the extent 

necessary to allow the transaction to proceed, provided . . . that the 

exemption is required by the public interest” (Id.). 

The Department’s long-established policy has been to approve and grant 

antitrust immunity for alliance agreements if: 

(1) the agreements do not eliminate or substantially reduce 

competition and are not adverse to the public interest; and 

(2) a grant of immunity would be in the public interest and necessary 

for the parties to proceed with the transaction (Order 2006-12-

17, p. 8). 

The proposed alliance satisfies both prongs of this test. Given the 

new U.S.-Japan Open Skies agreement, the proposed alliance will not 

substantially reduce competition; to the contrary, it is in the public 

interest because it will facilitate Open Skies and promote interalliance 

competition. The Joint Applicants will not proceed with the transaction 

without antitrust immunity given the potential cost of private litigation. 

 
- 13 –

PUBLIC VERSION 

II. THE PROPOSED ALLIANCE WILL CREATE SIGNIFICANT CONSUMER BENEFITS BY 

EXPANDING AND INTEGRATING THE ONEWORLD NETWORK, AND WILL MAXIMIZE THE 

BENEFITS OF U.S.-JAPAN OPEN SKIES 

A. The Full Benefits Of U.S.-Japan Open Skies Will Not Be Realized 

Absent Strong Transpacific Interalliance Competition Among Star, 

SkyTeam And oneworld 

1. The Department Has Recognized That Interalliance 

Competition Is Necessary For Consumers To Receive The 

Maximum Benefits From Open Skies 

The proposed alliance is vital for oneworld to compete effectively 

with Star and SkyTeam. This increased interalliance competition will in 

turn enhance the benefits of the Department’s Open Skies policy – first by 

solidifying U.S.-Japan Open Skies, then by serving as a foundation for 

further liberalization across Asia. Without approval of the Joint 

Application, there would be no U.S.-Japan Open Skies, and thus no new access 

to Tokyo’s two gateway airports – Narita and Haneda. Star and SkyTeam –

which both operate connecting hubs at Seoul with antitrust immunized 

partners (Asiana and Korean Airlines, respectively), and which both operate 

own-metal connecting hubs at Narita – would continue to be advantaged by the 

regulatory imbalance created by the current U.S.-Japan bilateral agreement 

to the detriment of consumers, and oneworld would continue to struggle as 

the smallest of the three global alliances. 

 
- 14 –

PUBLIC VERSION 

The Department focused on interalliance competition in the Star case, 

holding that “any consumer benefits created by a large multilateral 

immunized alliance . . . are likely to be greater in the face of the 

enhanced competition made possible by a more open air services agreement 

between the U.S. and Europe” (Order 2006-12-17, p. 9).3

 SkyTeam relied on 

this language to support the merger of its two existing transatlantic joint 

ventures between Delta/Air France and Northwest/KLM (Joint Application, DOTOST-2007-28644, 6/28/07, pp. 38-39). This is no less true across the 

Pacific – approval of the alliance agreements proposed here will give all 

three global alliances a strong foundation for competing against each other. 

It is beyond question that the creation of an immunized transpacific 

oneworld joint venture will generate significant consumer benefits. 

2. Allowing oneworld To Operate As An Integrated Joint Venture 

Will Drive All Three Globally Branded Alliances To Deliver 

Maximum Consumer Benefits 

In previous dockets, The Brattle Group demonstrated that oneworld’s 

inability to compete effectively across the Atlantic as an integrated 

alliance is preventing consumers from enjoying the full measure of public 

benefits associated with the Department’s Open Skies policy. The Brattle 

Group performed this analysis a number of different ways across several time 

periods – and the results were always consistent with the following 

conclusions: 

 

                                                           

3

 See also Order 2005-2-14, p. 19 (holding that “[a]n award to American in 

[the 2006 U.S.-China case] would also promote interalliance competition 

because it would permit the oneworld alliance, of which American is a 

member, to gain more access to the important China market. The other two 

major international aviation alliances have significantly more access, since 

Northwest is a member of the SkyTeam alliance, and United is a member of the 

Star alliance”). 
- 15 –

PUBLIC VERSION 

 Without competition from a third immunized alliance, the decline of 

traditional interlining has led to a dwindling of the number of 

significant transatlantic markets with more than two strong 

competitors (AA Surreply, DOT-OST-2004-19214, 7/15/05, Exhibit SUR2, p. 13; AA Answer, DOT-OST-2004-19214, 6/24/05, p. 36); and 

 The lower fares consumers should be enjoying as a result of Open 

Skies bilateral agreements were not materializing in the absence of 

strong interalliance competition from oneworld (AA Answer, DOT-OST2004-19214, 6/25/05, p. 36). 

The positive trends that the Department found from immunized alliances 

in 1999 and 2000 began to disappear as the lack of interalliance competition 

across the Atlantic stifled the benefits of Open Skies. Just as final 

approval of oneworld’s application for transatlantic antitrust immunity will 

break the Star/SkyTeam transatlantic network duopoly, the JBA will prevent 

an entrenched Star/SkyTeam duopoly from forming across the Pacific. 

B. The Proposed Alliance Will Create Significant New Consumer 

Benefits 

Since its creation, oneworld has been severely hampered in its ability 

to deliver the full range of possible consumer benefits because it does not 

operate with any substantial grant of antitrust immunity. Absent antitrust 

immunity for American and JAL, pro-competitive coordination is effectively 

precluded because of the threat and potential cost associated with defending 

against antitrust litigation. Moreover, the lack of metal neutrality 

prevents carriers – even those in an alliance – from acting as a truly 

integrated network because self-interest is not always aligned with the 

alliance’s collective best interest. This will be remedied by the 

implementation of the American/British Airways/Iberia joint business 

agreement across the Atlantic pending in DOT-OST-2008-0252, and by the JBA 

at issue here between the Joint Applicants on Pacific city-pairs. 

 
- 16 –

PUBLIC VERSION 

In Star II (DOT-OST-2008-0234), the Department concluded that a metal 

neutral joint venture like the JBA is “likely to create substantial public 

benefits, and that a grant of antitrust immunity was necessary to realize 

those benefits” (Order 2009-4-10, pp. 17-18). The Department found that the 

alliance agreements “would likely achieve efficiencies that would facilitate 

the introduction of new capacity, give consumers more travel options and 

shorter travel times, and reduce fares” (Id. at 5). The Department 

concluded that the public interest required a grant of antitrust immunity so 

that “members of the alliance [could] incorporate sales and distribution 

cooperation into the agreements to allow the applicants to pursue the full 

range of efficiencies possible under the venture, which would enhance the 

overall consumer benefits of the alliance” (Id.). Antitrust immunity 

“enables the Joint Applicants to coordinate fares, services, and schedules 

so that consumers are offered a broader array of choices within the alliance 

than could be offered without immunity” (Id. at 10). The result – as the 

Department noted – would be consumer benefits for passengers on both nonstop 

and connecting services (Id.). The same is true here. 

1. The Metal Neutrality Created By The JBA Is Essential To 

Facilitating An Integrated Transpacific oneworld Network 

Without metal neutrality, participants in an alliance operate for the 

benefit of their own operations – not the overall alliance network. Thus 

American and JAL today have an interest in carrying traffic across the 

Pacific on their own metal, rather than utilizing their combined operations 

to maximize consumer benefits. A joint venture eliminates this inefficiency 

by creating metal neutrality – a commercial indifference as to the operating 

carrier in an itinerary marketed by the alliance. Antitrust immunity is 

essential to the formation of these joint ventures, as the Department has 

recognized in prior cases (See, e.g., Order 2009-7-10, p. 10). 
- 17 –

PUBLIC VERSION 

For example, American and JAL each operate a daily nonstop flight 

between New York-JFK and Tokyo-Narita, and these flights depart within 30 

minutes of each other.4

 Absent a joint venture, there would be no incentive 

for either carrier to change its departure time (which is optimally set for 

local passengers), as it would likely result in lower onboard revenue for 

the carrier moving its flight even though it would generate more revenue for 

the two carriers combined. Revenue sharing in a metal neutral joint venture 

removes this inefficient disincentive, allowing the carriers to spread out 

their operations, giving local passengers more flexibility in their 

schedule, while providing enhanced connecting opportunities for flow 

passengers. 

2. The Proposed Alliance Will Create Expanded And Enhanced 

Route And Schedule Options 

With a closely integrated alliance, including the JBA, the Joint 

Applicants will have greater opportunities to launch new service and enhance 

their existing route and schedule options. New transpacific routes will be 

possible, making oneworld more competitive with Star and SkyTeam. Existing 

transpacific service can be optimized to provide more value to both local 

and connecting passengers. 

Competition in behind/beyond routes will be enhanced as well, as 

oneworld’s integration will create new competition against the existing Star 

and SkyTeam transpacific networks. Antitrust immunity will allow the Joint 

Applicants to offer lower fares and an improved product to the more than 11 

million annual passengers traveling between the U.S. and Asia, including 

those flying between the over 15,000 new global airport pairs that will be 

added to oneworld’s immunized network. 

                                                           

4

 AA 167 departs New York at 1130, and arrives in Tokyo at 1535, while JL 5 

departs New York at 1200 and arrives in Tokyo at 1620. 
- 18 –

PUBLIC VERSION 

When the Department approved the joint venture proposed in Star II, it 

cited benefits to consumers through a “[s]ignificant reduction of double 

marginalization . . . exerting downward pressure on fares and providing a 

wider range of fares” (Order 2009-7-10, p. 15). For instance, Professor Jan 

K. Brueckner analyzed the development of the United/Lufthansa alliance from 

its initial non-immunized phase through the implementation of a joint 

venture, and found that “pure alliance membership reduces price by 4%, 

codesharing by a further 7%, and antitrust immunity by an additional 16% 

over codesharing” (J.K. Brueckner, International Airfares in the Age of 

Alliances: The Effects of Code-Sharing and Antitrust Immunity, Review of 

Economics and Statistics 85, 105-118 (Feb. 2003)). 

 a. New Transpacific Routes And Service 

Approval and antitrust immunity for the alliance agreements and the 

JBA will strengthen the Joint Applicants’ ability to maintain and expand 

their nonstop services on transpacific routes, particularly given the high 

cost of providing international air service and an extremely challenging 

economic environment in which industry losses routinely reach the billions. 

Econometric and other empirical analyses of transatlantic alliances 

suggests that the JBA will lead to increases in nonstop service, 

particularly on hub-to-hub routes where more seats across the Pacific will 

be needed to accommodate the larger volumes of connecting traffic generated 

by the Joint Applicants’ expanded network (See R. Bennett et al., 

International Airline Alliance Development (July 2009), pp. 40-41). There 

is abundant evidence that “following previous ATI approvals, alliances added 

or expanded non-stop service between [their] U.S. and European hubs” (C. 

Shapiro & T. Sullivan, Airline Antitrust Immunity, DOT-OST-2004-19214, 

7/6/05, p. 13). 
- 19 –

PUBLIC VERSION 

For example, the United/Lufthansa immunized alliance doubled the 

number of U.S.-Germany nonstop routes and frequencies that they operated 

between 1996 (when the carriers were granted immunity) and 2008, including 

additional frequencies on the Chicago/Washington-Frankfurt hub-to-hub 

routes, and new services at secondary U.S. and German gateways (such as 

Boston-Munich and Seattle-Frankfurt). The carriers’ rate of capacity 

increase far exceeded the growth in local O&D passengers on U.S.-Germany 

nonstop routes – this is necessary because the alliance sets capacity levels 

to accommodate the increased volume of flow traffic being attracted by the 

improved network. 

This impact can also be seen on the difference in capacity growth 

within the Delta/Air France alliance on routes that were included and 

carved-out from antitrust immunity. On routes without a carve-out, seat 

capacity increased between 17% and 26%, depending on the measurement. In 

contrast, on carve-out routes, capacity changed between -12.4% and 1.6% 

(Joint Applicants Answer to DOJ Comments, DOT-OST-2008-0252, 1/11/10, 

Exhibit 3, p. 3). 

Likewise, as American and its European oneworld partners pointed out 

in DOT-OST-2008-0252: 

“Northwest (now Delta) and KLM operate twice as many 

daily flights and seats between Amsterdam and Detroit 

as American and Iberia operate between Miami and 

Madrid despite the fact that the DTW-AMS local market 

is one-third the size of MIA-MAD. This is because the 

highly integrated Northwest/KLM alliance requires 

capacity on this route to accommodate flow traffic, 

leading to increased capacity despite the fact that 

the carriers face no nonstop competition on the route” 

(Supplemental Comments, 9/8/09, p. 5). 

In short, the proposed alliance will facilitate more transpacific flights 

for oneworld customers – creating benefits for both local and connecting 

passengers. 
- 20 –

PUBLIC VERSION 

 b. New Behind/Beyond Connectivity 

The proposed alliance will also create better behind/beyond 

connectivity with an integrated American/JAL network. These new and 

improved connections will allow oneworld to be more competitive with Star 

and SkyTeam on transpacific routes, as well as for global corporate 

accounts. 

 i. New And Improved Connections 

By approving and granting antitrust immunity for the proposed 

alliance, the Department will enable American and JAL to significantly 

expand their individual networks by implementing the metal-neutral JBA joint 

venture. JAL’s network will add 65 unique points to American’s Asia network 

(which is currently limited to just Tokyo and Shanghai), while American will 

add 232 unique points to JAL’s network in North and South America. In 

total, this will create 15,080 new integrated airport-pairs. 

 ii. Competition With Star/SkyTeam 

An improved network is critically important for oneworld to be able to 

compete with Star and SkyTeam in the transpacific market. Today, Star and 

SkyTeam have integrated hub operations at Narita (United and Delta) and 

Seoul (United/Asiana and Delta/Korean). oneworld has neither. American 

currently serves just two cities in Asia – Tokyo and Shanghai (with Beijing 

service scheduled to begin later this year), while JAL serves nine cities in 

North and South America. By expanding and integrating the American/JAL 

network, consumers will for the first time enjoy the benefits of three 

competing networks – resulting in improved service and lower fares. 

 

 
- 21 –

PUBLIC VERSION 

3. Corporate Accounts 

The impact of oneworld’s lack of network integration is clearly seen 

in the disparity between its corporate contracts and those offered by Star 

and SkyTeam. Over the years, global corporate customers (comprised entirely 

of time-sensitive business travelers) have moved away from dealing with 

individual airlines and toward alliance contracts. These corporate 

customers – which can represent nearly a quarter of a network airline’s 

revenue – employ corporate travel managers to oversee their multi-million 

dollar budgets. Corporate travel managers are extremely sophisticated and 

understand the importance of alliances and the depth of their integration. 

In fact, some corporations are now requiring alliance bids to be from an 

immunized grouping – virtually taking oneworld out of the picture. 

oneworld’s current inability to provide a fully integrated alliance bid is 

harmful both to consumers and to the Joint Applicants. 

To be competitive when a corporate customer requests a bid, an 

alliance must be prepared to offer three things – simplicity, discounts and 

access to a global network. Even those corporate customers receptive to a 

non-immunized oneworld bid provide constant feedback that Star and SkyTeam 

are able to use their antitrust immunity to offer superior, fully integrated 

discount programs. In contrast, the oneworld product has been little more 

than stapling individual carrier contracts together in an alliance wrapper. 

Such a product cannot effectively compete in the marketplace, and despite 

vigorous efforts between oneworld’s commercial and legal teams to find a 

solution, the lack of antitrust immunity has resulted in little or no 

progress being made. 

 
- 22 –

PUBLIC VERSION 

Revenue sharing under the JBA will also create the commercial 

incentives necessary to promote and sell integrated alliance products. In a 

non-immunized environment, one airline has no reason to offer an “alliance” 

incentive to the customer because that would increase its own cost of sale 

without a corresponding increase in revenue. The JBA will allow oneworld to 

offer a much more attractive corporate product for transpacific and global 

accounts.

4. Combinable Fares 

The JBA will also benefit consumers through fare combinability – the 

ability to put itineraries together using one carrier for the outbound 

transpacific segment and another carrier for the return. Commercial and 

legal realities prevent airlines from creating combinable fares absent metal 

neutrality. While oneworld has been able to test limited fare combinability 

in smaller non-home countries (e.g., Italy, where no oneworld carrier is 

based), diversion and disruption of yield management have prevented the 

alliance from moving forward with this program on a larger scale. Absent 

fare combinability, the only way for a customer to enjoy the benefits of 

cheaper round trip fares is to select a single-metal online itinerary – 

limiting the number of frequencies available. If the customer wants the 

benefit of a combined schedule, one-way fares must be used – resulting in a 

far higher overall price. One customer reported to American that he “would 

fly AA in a heartbeat” if oneworld had combinable fares. In short, fare 

combinability gives the customer the best of both worlds – access to the 

alliance with a combined schedule and discounted fares.5

                                                           

5

 This is one of many reasons why a number of studies have concluded that 

truly integrated antitrust immunized alliances deliver lower fares than 

codesharing arrangements alone (See, e.g., Jan K. Brueckner and W. Tom 

Whalen, The Price Effects of International Airline Alliances, Journal of Law 

& Economics, 43 (2) (2000), pp. 503-545). 
- 23 –

PUBLIC VERSION 

These benefits, however, cannot be delivered without metal neutrality. 

Yield management of round trip fares requires a carrier to take expected 

load factors on both segments into consideration.6

 Absent an exchange of 

yield management information, it would be difficult to ensure balance in 

city-pairs where both carriers have a significant presence. The regular 

exchange of yield management information between airlines would present a 

significant risk of litigation given the competitive sensitivity of that 

data. As a result, despite the pro-competitive benefits of fare 

combinability, a non-immunized alliance faces extreme difficulties in 

overcoming the legal and commercial disincentives. 

5. Joint Procurement

oneworld’s joint procurement efforts have – to date – been hampered by 

concerns about potential antitrust litigation, even though the carriers 

believe the activity would be pro-competitive in nature. With antitrust 

immunity, the Joint Applicants will be able to fully coordinate their joint 

purchasing in an effort to reduce costs – something made even more critical 

with jet fuel at unprecedented levels. These activities may include 

obtaining volume discounts, common specifications for goods and services, 

joint bidding and negotiations with suppliers, and the use of standardized 

contracts for acquiring goods and services. Costs can be reduced across a 

wide range of products and services, such as maintenance, field station 

support, catering services, aircraft and ground equipment acquisition and 

sales, distribution channels, fuel and information technology. 

 

                                                           

6

 For example, a carrier may hold open low-value inventory on a relatively 

full flight if it is linked to the sale of a return flight expected to 

depart with a large number of empty seats. 
- 24 –

PUBLIC VERSION 

Additionally, the ability to unify sales forces is an often-cited 

benefit of the Northwest/KLM joint venture (See, e.g., Jay Boehmer, Air 

France, Delta Join Up: Carriers To Share Transatlantic Sales Strategy, Route 

Expansion Plans And Bottom Line, BTNonline, 10/22/07). The JBA will allow 

American and JAL to do the same – with each carrier focusing its sales 

efforts in a single region. Not only will this reduce costs, it will 

strengthen the metal neutrality associated with the joint venture, as 

competing goals will be replaced by a common economic interest. 

III. U.S.-JAPAN OPEN SKIES WILL ENSURE THAT THE PROPOSED ALLIANCE WILL NOT 

SIGNIFICANTLY REDUCE COMPETITION 

The proposed alliance will create public benefits of all kinds – 

expanded networks, improved itineraries and more integrated product 

offerings; moreover, it will not significantly reduce competition in any 

relevant market. The proposed alliance will improve global and transpacific 

network competition by allowing oneworld to compete with Star and SkyTeam on 

a comparable regulatory and commercial footing. At the same time, the 

enhanced competitive conditions resulting from the landmark U.S.-Japan Open 

Skies Agreement will prevent the Joint Applicants from exercising market 

power on any overlapping transpacific route. Accordingly, the alliance 

agreements meet the Department’s standard for approval and antitrust 

immunity.

 
- 25 –

PUBLIC VERSION 

A. The Proposed Alliance Will Enhance Global And Transpacific 

Network Competition By Facilitating U.S.-Japan Open Skies

The proposed alliance will allow oneworld to become a third immunized 

alliance capable of competing effectively with Star and SkyTeam. 

Interalliance competition is extremely important, with more than 80% of the 

world’s 60 largest airlines being members of a globally branded alliance. 

Thus, approval of the proposed alliance will create – not reduce – 

competition in both the global and transpacific marketplace. The successful 

creation of strong interalliance competition across the Pacific – a direct 

result of the Department’s Open Skies Policy – could well lead to a 

deregulation of aviation markets elsewhere, particularly in Asia. 

B. The Proposed Alliance Will Not Significantly Reduce Competition 

In Any Global, Regional Or Country-Pair Market 

 1. Global And Transpacific Interalliance Competition 

 a. Global 

The addition of a transpacific joint venture to oneworld’s network is 

essential to expand consumer choice and enhance competition in the global 

marketplace – something U.S.-Japan Open Skies is necessary to achieve. 

Today, SkyTeam has a significant network advantage in Asia, as the 

Delta/Northwest merger has given it two integrated hub networks – one over 

Narita with Northwest’s Pacific Franchise, and the other over Seoul with the 

Delta/Korean Air immunized alliance. Star stands poised to compete with 

SkyTeam with its combination of the existing immunized United/Asiana 

alliance at Seoul and proposed United/Continental/ANA alliance at Narita. 

The proposed alliance will give oneworld a competing Narita hub – critical 

to the sustainability of three competing global networks. 

 
- 26 –

PUBLIC VERSION 

Antitrust immunity will give consumers more travel options, shorter 

travel times and reduced fares and will likely accelerate the introduction 

of new capacity on transpacific routes. Specifically, approval of this 

Joint Application will add 65 new points to the integrated oneworld network 

in Asia, as well as 232 new points in North/South America for integrated 

transpacific service. Together, the Joint Applicants will account for an 

extremely small percentage of the global network market, and oneworld as a 

whole is the smallest of the three global alliances. 

 b. Transpacific 

A large number of carriers compete on U.S.-Asia routes across the 

Pacific, with no single carrier or alliance enjoying a dominant share. 

Approval of this Joint Application will not substantially lessen that 

competition. More than 20 international carriers – including the four 

largest U.S. network airlines – operate scheduled nonstop passenger service 

between 17 points in the U.S. and 19 points in Asia. These services are 

supported by codeshare agreements creating online itineraries in thousands 

of behind- and beyond-gateway O&D city pairs. After approval of this Joint 

Application, 97% of U.S.-Asia O&Ds and 99% of U.S.-Asia passengers will 

continue to enjoy the benefits of at least three competing options and/or 

will experience no change in the number of competitive offerings. 

 
- 27 –

PUBLIC VERSION 

In fact, the proposed alliance will link the 3rd and 11th largest 

carriers (measured by capacity) in the U.S.-Asia market, or the 9th and 10th 

largest carriers (measured by U.S. point-of-origin bookings) (See Joint 

Application, DOT-OST-2009-0350, 12/23/09, Exhibit JA-8, p. 2). Thus the 

transpacific market is not concentrated, and the combination of smaller 

competitors like American and JAL will only serve to improve network 

competition. Together, the Joint Applicants will account for just 22.4% of 

the transpacific network market (just 9.8% of U.S. point-of-origin traffic) 

(Joint Application, DOT-OST-2009-0350, 12/23/09, Exhibit JA-8, p. 2), well 

within the Department’s precedents in prior immunity cases. 

 2. U.S.-Japan Competition 

Competition among individual airlines and alliances for U.S-Japan 

services is intense. Between the U.S. and Japan, Delta/Korean is the 

largest competitor measured by capacity, with 31% of seats in the market. 

The proposed United/Continental/ANA alliance will account for 31% of U.S.-

Japan seats as well. Today, JAL accounts for 24.6% of U.S.-Japan seats, 

while American operates 8.8%, which means the proposed alliance will bring 

oneworld into competitive parity with Star and SkyTeam with 33%. 

On a booking level, the proposed alliance will also create competitive 

parity. Today, American carries just 6.3% of U.S.-Japan passengers – far 

less than Delta (26.0%) or United (14.7%). With the proposed alliance (and 

United/Continental/ANA), oneworld will account for 38.0% of U.S.-Japan 

bookings, followed by SkyTeam 29.9% and Star 28.0%. That level of 

competitive choice is unmatched in any other country-pair. Thus the 

proposed alliance will not harm competition between the U.S. and Japan, and 

is well within the Department’s precedent in prior immunity cases (See, 

e.g., Order 2009-4-5, pp. 8-10).
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PUBLIC VERSION 

C. City-Pair Competition 

Individual city-pair competition between the U.S. and Japan will also 

remain robust with the immunized American/JAL alliance. The Joint 

Applicants operate overlapping nonstop service in just three city-pairs: 

New York-Tokyo, Los Angeles-Tokyo and Chicago-Tokyo. Each of these citypairs will continue to have competing service among Star, SkyTeam and 

oneworld, making this proposed alliance uniquely pro-competitive. 

1. New York-Tokyo 

New York-Tokyo accounts for approximately 465 bookings per day each 

way, and five carriers operate daily nonstop service with Boeing 777 

aircraft: American, JAL (9 weekly), ANA, Continental and Delta. After the 

Department grants immunity to oneworld and Star, there will still be three 

independent competitors and vibrant competition on the route. Star will 

account for 46.3% of all bookings, while oneworld will account for 45.0%. 

Delta and other airlines accounted for nearly 10% even before Delta relaunched its service in mid-2009.7

This competitive overlap is well within the Department’s precedent. 

The Department has granted antitrust immunity on many city-pairs with three 

nonstop post-transaction competitors (Order 2009-7-10, DOT-OST-2008-0234, p. 

18, holding that “we will not impose carve outs in markets that only shift 

from four to three, or from three to two, nonstop competitors, as we are not 

convinced that these pose a risk of substantial reduction in competition”), 

and 45.0% is far below the numbers in prior proceedings (See, e.g., Order 

2009-4-5, pp. 12-13). There is no potential for harm to competition in this 

city-pair. 

 

                                                           

7

 Since June 2009, Delta’s share has increased significantly as a result of 

re-launching nonstop service. 
- 29 –

PUBLIC VERSION 

2. Los Angeles-Tokyo 

Los Angeles-Tokyo accounts for approximately 595 bookings per day each 

way, and six carriers operate daily nonstop service: American (Boeing 777), 

JAL (Boeing 777), ANA (Boeing 777), Delta (Boeing 747), Korean (Boeing 777) 

and Singapore (Boeing 747). After the Department grants immunity to 

oneworld and Star, there will still be four independent competitors and 

vibrant competition on the route. SkyTeam will account for 34.2% of all 

bookings on the route, Star (except Singapore Airlines, which does not have 

antitrust immunity) will account for 24.1%, Singapore 20.4% and oneworld 

20.3%. Other airlines will account for approximately 1.0%. 

This competitive overlap is well within the Department’s precedents. 

The Department has granted antitrust immunity on many city-pairs with four 

nonstop post-transaction competitors (Order 2009-7-10, DOT-OST-2008-0234, p. 

18, and oneworld’s 23.0% share is the smallest of the four major 

competitors. 

3. Chicago-Tokyo 

Chicago-Tokyo accounts for approximately 122 bookings per day each 

way, and is a route served nonstop primarily to accommodate flow traffic. 

Four carriers operate daily nonstop service: American (Boeing 777), JAL 

(Boeing 777), ANA (Boeing 777) and United (Boeing 747). After the 

Department grants immunity to oneworld and Star, there will still be two 

independent competitors and vibrant competition on the route. Star will 

account for 49.7% of all bookings, while oneworld will account for 44.2%. 

Delta and other airlines will account for approximately 6.1%. 

 
- 30 –

PUBLIC VERSION 

Moreover, for both Star and oneworld, Chicago-Tokyo is a hub-to-hub 

route. As discussed in Part II.B.2.a, above, immunized alliance partners 

have a strong incentive to add capacity on such hub-to-hub routes, and they 

have done so in the past. Capacity increases yield numerous benefits for 

passengers, including more travel options and lower fares. Chicago-Tokyo is 

a thin local market to begin with, and convenient one-stop options are 

offered by Delta via Minneapolis/St. Paul, Detroit, Seattle, Portland and 

San Francisco. This competitive overlap is well within the Department’s 

precedents. The Department has granted antitrust immunity on many citypairs with two nonstop post-transaction competitors (Order 2009-7-10, DOTOST-2008-0234, p. 18, and 44.2% is far below the numbers in some prior 

proceedings (See, e.g., Order 2009-4-5, pp. 12-13). There is no potential 

for harm to competition in this city-pair. 

IV. THE JOINT APPLICANTS WILL NOT PROCEED WITH THE PROPOSED ALLIANCE 

ABSENT ANTITRUST IMMUNITY

Immunizing the proposed alliance is the only way to enable the Joint 

Applicants to compete on equal footing with Star and SkyTeam. Greater 

integration between American and JAL through the JBA will create vibrant 

interalliance competition, as oneworld will be able to deliver significant 

service and fare improvements to customers. Because the full network 

benefits of the proposed alliance cannot be realized absent a grant of 

antitrust immunity, withholding approval would essentially preclude 

oneworld’s chances for long-term success in the alliance marketplace. The 

biggest losers would be the customers who seek interalliance competition, 

but only have two choices – Star and SkyTeam – at present. 

 
- 31 –

PUBLIC VERSION 

The JBA cannot be implemented in the absence of antitrust immunity. 

Although American and JAL have already agreed to the most important 

components of the relationship, such as governance, geographic scope, and 

the process for determining how revenues are pooled and shared, their 

negotiations cannot be completed without an exchange of confidential and 

highly sensitive transpacific segment information and competitive data. Such 

an exchange prior to a grant of antitrust immunity would not only carry some 

risk under the antitrust laws, but would also create a significant 

commercial risk if there is any doubt as to whether the Department will 

approve the transaction. Accordingly, the Joint Applicants urge the 

Department to approve this application and immunize the proposed alliance 

agreements so that the parties can finalize and implement their joint 

venture and consumers can enjoy the benefits of integration. 

V. OTHER APPROVAL ISSUES, CONDITIONS AND INFORMATION 

The Joint Applicants are providing the following additional 

information typically furnished to the Department for the purpose of 

analyzing applications for antitrust immunity 

A. Document Production And Responses To Interrogatories. 

The Joint Applicants will submit separately, under a joint motion for 

confidential treatment, documents responsive to the criteria used in 

previous antitrust immunity dockets, including the U.S.-U.K. Alliance Case

(DOT-OST-2001-11029), SkyTeam (DOT-OST-2004-19214, Star (DOT-OST-2005-

22922), SkyTeam II (DOT-OST-2007-28644), Star II (DOT-OST-2008-0234) and 

oneworld (DOT-OST-2008-0252) (Exhibit JA-28). In addition, the Joint 

Applicants are providing written responses to interrogatories similar to 

those issued by the Department in previous antitrust immunity proceedings. 

 
- 32 –

PUBLIC VERSION 

B. Transpacific Routes 

The transpacific routes flown by the Joint Applicants are identified 

in Exhibit JA-8. The Joint Applicants anticipate that they will continue 

serving these routes after the alliance agreements are approved, and they do 

not have plans to change their services that are contingent on approval 

being obtained. The carriers will continue to adjust their schedules 

depending on market conditions and competitive opportunities.

C. Transpacific Carriers Within The Three Alliances 

Star has four transpacific members, including United and ANA (each of 

which operates a Narita hub) and Continental (which operates a hub in Guam), 

and Asiana (which has antitrust immunity with United and operates a hub in 

Seoul). SkyTeam has three transpacific members, including Delta (which 

operates a hub at Narita) and Korean Airlines (which has antitrust immunity 

with Delta and also operates a hub in Seoul). oneworld has three 

transpacific members, but no integrated transpacific alliance network. 

D. Codeshare Agreements 

The current codeshare agreements between each of the Joint Applicants 

and non-oneworld carriers are listed in Exhibit JA-9. 

E. Relationship To oneworld 

The proposed American/JAL alliance includes two of oneworld’s transpacific members and will primarily affect transpacific markets. Although 

the American/JAL alliance will be an integral part of oneworld, it will not 

significantly influence operations of other oneworld members that do not 

operate competing transpacific service to Japan. oneworld will therefore be 

well positioned to coordinate and optimize U.S.-Japan service to the benefit 

of its member carriers and their passengers. 
- 33 –

PUBLIC VERSION 

oneworld’s membership currently includes American, British Airways, 

Cathay Pacific, Finnair, Iberia, Japan Airlines, LAN, Malev, Mexicana, 

Qantas, and Royal Jordanian. American has separate antitrust immunity with 

Finnair (DOT-OST-2002-12063) and with LAN/LAN Peru (DOT-OST-2004-19964), and 

is seeking joint antitrust immunity with British Airways, Iberia, Finnair, 

and Royal Jordanian in DOT-OST-2008-0252. 

It is possible that as the JBA expands in geographic scope, other 

oneworld carriers could be included in a future application. In the case of 

the LAN carriers, this would become much easier if the United States were 

able to reach Open Skies agreements with Argentina and Ecuador, allowing 

American to seek antitrust immunity with all four LAN affiliates. It is 

also possible that American and JAL could seek to include Qantas in a future 

application, as the U.S. and Australia now have an Open Skies agreement. 

Inclusion of Cathay Pacific will not be possible until the U.S.-Hong 

Kong market is fully liberalized. However, this will not create tension 

within the JBA, as American does not operate service to Hong Kong, and thus 

will not have competing traffic flows to Asia over a non-JBA gateway. 

Likewise, inclusion of Mexicana is not presently possible; the U.S.-Mexico 

air transport agreement, although not highly restrictive, is not Open Skies, 

and thus prevents Mexicana from joining the immunized alliance at this time. 

F. Hub Airports 

American operates hubs at Dallas/Fort Worth, Chicago O’Hare and Miami. 

JAL operates hubs at Narita and Haneda. 

 
- 34 –

PUBLIC VERSION 

G. Significant Service And Equipment Changes 

The Joint Applicants have not finalized any schedule changes to be 

made after the proposed alliance is approved and implemented. The Joint 

Applicants may adjust their schedules in the future depending on market 

conditions and opportunities presented by the competitive environment 

H. Competitive Access To Non-U.S. Gateway Airports 

Competitive access to the Joint Applicants’ non-U.S. gateway airports 

will be addressed in response to the standard interrogatories in a separate 

submission.

I. Impact On Revenue 

The proposed alliance is an integral element of each carrier’s global 

network ambitions. The carriers anticipate that the development and 

expansion of their alliance will generate additional traffic and revenue, 

enhance operating efficiencies, and have a positive impact on system 

profitability. 

J. U.S. Labor Issues 

American believes that the transaction raises no significant labor 

issues. American and JAL will remain independent. No significant impact on 

unionized employees is anticipated under the alliance and coordination 

agreements. The applicants believe that the long-term impact of the 

transaction will be positive for all existing employees for new job 

creation. 

K. Computer Reservations Systems

Consistent with Department precedent, the Joint Applicants request 

that the grant of antitrust immunity encompass the presentation and sale of 

their services in computer reservations systems and the operation of their 

internal reservations systems. 
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PUBLIC VERSION 

L. Civil Reserve Air Fleet

The alliance agreements between American and JAL will have no impact 

on American’s CRAF commitments. 

M. CRS Booking Data

This data will be provided in response to the standard document 

requests. 

N. Resubmission Of Alliance Agreements

The Joint Applicants will accept the Department’s general condition 

requiring the carriers “to resubmit for review their Alliance Agreements 

five years from the data of issuance of the final order” (Order 2002-11-12, 

p. 18).

O. Conditions

The Joint Applicants will accept the Department’s standard conditions 

attached to previous grants of antitrust immunity relating to: (1) nonparticipation in certain IATA price-related tariff coordination activities; 

(2) O&D Survey data reporting requirements; (3) operation under a common 

name or brand; and (4) the submission of any subsequent subsidiary 

agreements implementing the Alliance Agreements. With respect to the JBA, 

the Joint Applicants will accept the conditions that the Department attached 

to its final order granting antitrust immunity to the expanded SkyTeam 

alliance requiring implementation within 18 months (Order 2008-5-32, pp. 4-

6, App. A). Those conditions required: (1) submission of evidence that the 

JBA has been implemented within 18 months; and (2) submission of a status 

report within 12 months if the prior condition has not already been met.

 
- 36 –

PUBLIC VERSION 

CONCLUSION 

Joint Applicants have presented the Department with one of the most 

pro-competitive proposed alliances in the history of antitrust immunity 

proceedings. Approval of the Joint Application will facilitate the 

implementation of a new U.S.-Japan Open Skies agreement, will link two 

complimentary networks and give oneworld its first truly integrated 

transpacific hub network to compete with Star and SkyTeam, and involves 

overlaps on just three city-pairs accounting for less than a million 

bookings per year where there will be no less than two nonstop posttransaction competitors on each route. Accordingly, the Joint Applicants 

ask that the Department move promptly to approve the proposed alliance and 

grant immunity under 49 U.S.C. §§ 41308 and 41309. 

 Respectfully submitted, 

 

CARL B. NELSON, JR. WILLIAM KARAS 

Associate General Counsel CAROL GOSAIN 

R. BRUCE WARK Steptoe & Johnson LLP 

Associate General Counsel Attorneys for Japan Airlines 

JEFFREY A. OGAR 

Senior Attorney 

American Airlines, Inc. 

February 12, 2010 
INDEX OF JOINT EXHIBITS

JA-1 Alliance Agreement 

JA-2 Joint Business Agreement 

JA-3 Linking JAL’s Unique Asia Airports With Unique 

 U.S. Airports Served by American Will Add 9,752 

 Immunized U.S.-Asia Airport Pairs 

JA-4 The American/JAL Immunized Alliance Will Add 65 New Asia 

Airports To The Immunized Global Network 

JA-5 The Scope Of The Proposed Joint Venture Will Cover 

15,745 Transpacific Airport-Pairs And Approximately 17.1 

Million Annual Passengers 

JA-6 A Grant Of ATI To The American/JAL Alliance Will Not 

 Reduce The Intense Competition In The U.S.-Asia Market 

JA-7 Passengers Traveling On American/Japan Airlines 

 Nonstop Overlaps Will Continue To Benefit From 

 Significant Nonstop (And Other) Competition 

JA-8 Joint Applicants’ U.S. To International Routes 

JA-9 Joint Applicants’ International Codeshare Partners 

JA-10 Carriers Operating Scheduled International Services 

 At American’s Hubs And Gateway Cities 

JA-11 Joint Applicants’ U.S. To Asia Nonstop Routes 
EXHIBIT JA-1 

AMERICAN/JAPAN AIRLINES 

ALLIANCE AGREEMENT 

 



























EXHIBIT JA-2 

AMERICAN/JAPAN AIRLINES 

JOINT BUSINESS AGREEMENT 

Confidential Treatment Requested 

Under 14 CFR 302.12 
Linking JAL’s Unique Asia Airports With Unique U.S. Airports Served B

Will Add 9,750 New Immunized U.S. – Asia Airport Pairs

AA U i U S U i JAL New Immuni

zed AA

U

nique

U.S.

Airports

U

nique JAL

Asia Airports

New Immunized

U.S.‐Asia Airport

Pairs

150 X 65 = 9,750

• The 150 Unique AA U.S. Airports Account For A Combined 

Total of More Than 5 2 Million Passengers To/From Asia AnnuTotal of More Than

5.2 Million Passengers To/From Asia Annu

• JL’s 65 Unique Asia Airports Account For A Combined Total 

Of Approximately 11.7 Million Passengers To/From The U.S. An

SOURCE: OAG, December 2009; MIDT, Year 2009
Linking JAL Linking JAL s’ Unique Asia Airports With Unique International Airp

Unique Asia Airports With Unique International Airp

Served By American Will Add 15,080 New Global Immunized Airport 

AA Unique U.S.

and Unique JAL New Immunized U S ‐International International

Airports

Asia Airports U.S.‐International Airport Pairs

150

+ X 65 15 080

82

X 65 = 15,080

• The 150 Unique AA U.S. Airports Account For A Combined 

Total of More Than 5.2 Million Passengers To/From Asia Annua

• Th 82 AA U i I t ti l Ai t A t F A The 82 AA Unique International Airports Account For A

Combined Total Of 3.8 Million Passengers To/From Asia Annua

• JL’s 65 Unique Asia Airports Account For A Combined Total 

Of A i t l 11 7 Milli P T /F Th U S A 

SOURCE: OAG, December 2009; MIDT, Year 2009

Of Approximately 11.7 Million Passengers To/From The U.S. An
Linking JAL’s Unique Asia Airports With Unique U.S. Airports Serv

B A i Will Add 9 750 N I i d U S By 

American Will Add

9,750

New Immunize

d

U.S. – A i Ai t P 

A

sia Airpor

t

P

a

International Airports In Asia At Which JAL (But Not American) Operates

# Name Airport Code Country # Name Airport Co1 Akita Japan AXT Japan 34 Miyazaki Japan KMI 2 Amami

O Shima Japan ASJ Japan 35 Nagasaki Japan NGS 

3 Aomori Japan AOJ Japan 36 Nagoya( l) Int Japan NGO 

4 Asahikawa Japan AKJ Japan 37 Nagoya(Komaki) Japan NKM 

5 Bangkok (Intl) Thailand BKK Thailand 38 Nanki Shirahama Japan SHM 

6 Beijing(Capital) China PEK China 39 Niigata Japan KIJ 

7 Busan Rep. of Korea PUS Republic of Korea 40 Obihiro Japan OBO 8 Dalian China DLC China 41 Oita Japan OIT 

9 Fukuoka Japan FUK Japan 42 Okayama Japan OKJ 

10 Guangzhou China CAN China 43 Okinawa Japan OKA 11 Hakodate Japan HKD Japan 44 Osaka(Itami) Japan ITM 

12 Hanamaki Japan HNA Japan 45 Osaka(Kansai Intl) Japan KIX 13 Hangzhou China HGH China 46 Osaka(Kobe) Japan UKB 14 Hanoi Vietnam HAN Vietnam 47 Qingdao China TAO 15 Hiroshima(Intl) Japan HIJ Japan 48 Sapporo(Chitose) Japan CTS 

16 Ho Chi Minh City Vietnam Vietnam SGN Vietnam Vietnam 49 Sendai Japan SDJ 17 Hong Kong(Intl) China HKG China 50 Seoul(Gimpo Intl) Rep. of Korea GMP 

18 Ishigaki Japan ISG Japan 51 Seoul(Incheon Intl) Rep. of Korea ICN 

19 Izumo Japan IZO Japan 52 Shanghai (Hongqiao Intl) China SHA 

20 Kagoshima Japan KOJ Japan 53 Shanghai (Pu Dong Intl) China PVG 21 Kaohsiung Chinese Taipei KHH Chinese Taipei 54 Shizuoka Japan FSZ 

22 Kita Kyushu Japan KKJ Japan 55 Singapore(Changi) SIN 

23 Kochi Japan KCZ Japan 56 Taipei(Taoyuan Intl) Chinese Taipei TPE 

24 Komatsu Japan KMQ Japan 57 Takamatsu Japan TAK 25 Kuala Lumpur(Intl) Malaysia KUL Malaysia 58 Tianjin China TSN 

26 Kumamoto Japan KMJ Japan 59 Tokunoshima Japan TKN 27 Kume Jima Japan UEO Japan 60 Tokushima Japan TKS 28 Kushiro Japan KUH Japan 61 Tokyo(Haneda) Japan HND 

29 Manila Philippines MNL Philippines 62 Ube Japan UBJ 

SOURCE: OAG, December 2009

pp pp p 

30 Matsuyama Shikoku Japan MYJ Japan 63 Xiamen China XMN 31 Memanbetsu Japan MMB Japan 64 Yamagata Japan GAJ 

32 Misawa Japan MSJ Japan 65 Yonaguni Jima Japan OGN 

33 Miyako Jima Japan MMY Japan
Linking JAL Linking JAL s’ Unique Asia Airports With Unique U.S. Airports Serve

Unique Asia Airports With Unique U.S. Airports Serve

By American Will Add 9,750 New Immunized U.S. – Asia Airport Pai

U.S. Airports At Which American (But Not JAL) Operates

# Name Airport Code State # Name Airport Co

1 Abilene TX USA ABI Texas (TX) USA 26 Columbus(Intl) OH USA CMH 

2 Albuquerque NM USA ABQ New Mexico (NM) USA 27 Corpus Christi TX USA CRP 

3 Alexandria(Intl) LA USA AEX Louisiana (LA) USA 28 Dallas/Ft. Worth(Intl) TX USA DFW 

4 Amarillo TX USA AMA Texas (TX) USA 29 Dayton(Intl) OH USA DAY 

5 Atlanta(Intl) GA USA ATL Georgia (GA) USA 30 Denver(Intl) CO USA DEN 

6 Austin(Bergstrom Intl) TX USA AUS Texas (TX) USA 31 Des Moines IA USA DSM 

7 Baltimore(Intl) MD USA BWI Maryland (MD) USA 32 Detroit(Metro Wayne) MI USA DTW 

8 Baton Rouge LA USA BTR Louisiana (LA) USA 33 Dubuque IA USA DBQ 

9 Birmingham AL USA BHM Alabama (AL) USA 34 El Paso TX USA ELP 

10 Bloomington IL USA BMI Illinois (IL) USA 35 Evansville IN USA EVV 

11 Boston(Intl) Boston(Intl) MA USA BOS Massachussetts Massachussetts (MA) USA 36 Fayetteville(Regional) Fayetteville(Regional) AR USA XNA 12 Brownsville TX USA BRO Texas (TX) USA 37 Flint MI USA FNT 

13 Buffalo(Intl) NY USA BUF New York (NY) USA 38 Fresno(Yosemite Intl) CA USA FAT 

14 Burbank CA USA BUR California (CA) USA 39 Ft. Lauderdale(Intl) FL USA FLL 

15 Cedar Rapids/Iowa City IA USA CID Iowa (IA) USA 40 Ft. Myers(Southwest Fl Intl) FL USA RSW 

16 Champaign IL USA CMI Illinois (IL) USA 41 Ft. Smith AR USA FSM 

17 Charleston SC USA CHS South Carolina (SC) USA 42 Ft. Walton Beach FL USA VPS 

18 Charleston WV USA CRW West Virginia (WV) USA 43 Ft. Wayne IN USA FWA 

19 Charlotte NC USA CLT North Carolina (NC) USA 44 Grand Junction CO USA GJT 20 Chattanooga TN USA CHA Tennessee (TN) USA 45 Grand Rapids MI USA GRR 

21 Cincinnati(Intl) OH USA CVG Ohio (OH) USA 46 Green Bay WI USA GRB 

22 Cleveland(Intl) OH USA CLE Ohio (OH) USA 47 Greensboro/H.Pt/Win‐Salem NC USA GSO 

SOURCE: OAG, December 2009

23 College Station TX USA CLL Texas (TX) USA 48 Greenville/Spartanburg SC USA GSP 

24 Colorado Springs CO USA COS Colorado (CO) USA 49 Gulfport/Biloxi MS USA GPT 25 Columbia SC USA CAE South Carolina (SC) USA 50 Gunnison CO USA GUC 
Linking JAL’s Unique Asia Airports With Unique U.S. Airports Serv

B A i Will Add 9 750 N I i d U S By 

American Will Add

9,750

New Immunize

d

U.S. – A i Ai t P 

A

sia Airpor

t

P

a

# Name Airport Code State # Name Airport C

U.S. Airports At Which American (But Not JAL) Operates

# Name Airport Code State # Name Airport C

51 Hartford(Bradley Intl) CT USA BDL Connecticut (CT) USA 76 Lubbock(P. Smith Intl) TX USA LBB 

52 Houston(G.Bush Intl) TX USA IAH Texas (TX) USA 77 Madison(Dane County) WI USA MSN 

53 Houston(Hobby) TX USA HOU Texas (TX) USA 78 Manhattan KS USA MHK 

54 Huntsville/Decatur AL USA HSV Alabama (AL) USA 79 Marquette MI USA MQT 

55 Indianapolis IN USA IND Indiana (IN) USA 80 McAllen TX USA MFE 

56 Jackson WY USA JAC Wyoming (WY) USA 81 Memphis TN USA MEM 

57 Jackson‐Evers(Intl) MS USA JAN Mississippi (MS) USA 82 Miami(Intl) FL USA MIA 58 Jacksonville(Intl) FL USA JAX Florida (FL) USA 83 Midland/Odessa TX USA MAF 

59 Kahului Maui HI USA OGG Hawaii (HI) USA 84 Milwaukee WI USA MKE 

60 Kalamazoo MI USA AZO Michigan (MI) USA 85 Minneapolis/St. Paul(Intl) MN USA MSP 

61 Kansas City(Intl) MO USA MCI Missouri (MO) USA 86 Mobile AL USA MOB 

62 Key West FL USA EYW Florida (FL) USA 87 Moline IL USA MLI 

63 Killeen Gray AAF TX USA GRK Texas (TX) USA 88 Monroe LA USA MLU 

64 Knoxville TN USA TYS Tennessee (TN) USA 89 Monterey CA USA MRY 

65 La Crosse WI USA LSE Wisconsin (WI) USA 90 Montgomery AL USA MGM 

66 Lafayette LA USA LFT Louisiana (LA) USA 91 Montrose CO USA MTJ 

67 La ek C a es h rl ( eg o a ) (Regional) LA USA LCH Lou s a a i i n ( ) LA USA 92 Nas ( t ) hvill(Intl) TN USA BNA 68 Laredo TX USA LRD Texas (TX) USA 93 New Orleans(Intl) LA USA MSY 

69 Las Vegas(Intl) NV USA LAS Nevada (NV) USA 94 New York(Laguardia) NY USA LGA 

70 Lawton OK USA LAW Oklahoma (OK) USA 95 Newark/New York(Liberty) NJ USA EWR 

71 Lexington KY USA LEX Kentucky (KY) USA 96 Norfolk/Va.Bch/Wmbg VA USA ORF 

72 Lihue Kauai HI USA LIH Hawaii (HI) USA 97 Oklahoma City(Rogers) Oklahama USA OKC 

SOURCE: OAG, December 2009

73 Little Rock AR USA LIT Arkansas (AR) USA 98 Omaha NE USA OMA 

74 Longview TX USA GGG Texas (TX) USA 99 Ontario (Intl) CA USA ONT 

75 Louisville KY USA SDF Kentucky (KY) USA 100 Orlando(Intl) FL USA MCO 
Linking JAL’s Unique Asia Airports With Unique U.S. Airports Ser

B

y American Will Add 9,750 New Immunized U.S. –

Asia Air

port Pa

U.S. Airports At Which American (But Not JAL) Operates

# Name Airport Code State # Name Airport Code 

101 Palm Springs CA USA PSP California (CA) USA 126 Shreveport LA USA SHV 

102 P l ensacola FL USA PNS Fl id or a (FL) USA 127 S i fi ld Springfield IL USA SPI 103 Peoria IL USA PIA Illinois (IL) USA 128 Springfield MO USA SGF 

104 Philadelphia(Intl) PA USA PHL Pennsylvania (PA) USA 129 Steamboat Springs CO USA HDN 

105 Phoenix(Intl) AZ USA PHX Arizona (AZ) USA 130 St. Croix(Intl) US Virgin Islands STX 

106 Pittsburgh(Intl) PA USA PIT Pennsylvania (PA) USA 131 St. Louis(Intl) MO USA STL 

107 Portland OR USA PDX Oregon (OR) USA 132 St. Thomas(Intl) US Virgin Islands STT 

108 Raleigh/Durham NC USA RDU North Carolina (NC) USA 133 Syracuse NY USA SYR 

109 Reno NV USA RNO Nevada (NV) USA 134 Tallahassee FL USA TLH 

110 Richmond/Wmbg VA USA RIC Virginia (VA) USA 135 Tampa(Intl) FL USA TPA 

111 Rochester MN USA RST Minnesota (MN) USA 136 Texarkana AR USA TXK 

112 Rochester NY USA ROC New York (NY) USA 137 Toledo OH USA TOL 

113 Roswell NM USA ROW New Mexico (NM) USA 138 Traverse City MI USA TVC 

114 Sacramento(Metro) CA USA SMF California (CA) USA 139 Tucson AZ USA TUS 

115 Salt Lake City UT USA SLC Utah (UT) USA 140 Tulsa OK USA TUL 

116 San Angelo TX USA SJT Texas (TX) USA 141 Tyler TX USA TYR 

117 San Antonio TX USA SAT Texas (TX) USA 142 Vail/Eagle CO USA EGE 

118 San Diego(Intl) CA USA SAN California (CA) USA 143 Waco(Municipal) TX USA ACT 

119 San Jose CA USA SJC California California (CA) USA 144 Washington Washington (Reagan (Reagan Nat l)' DC USA DCA 120 San Juan(Intl) Puerto Rico SJU Puerto Rico (PR) USA 145 Washington(Dulles Intl) DC USA IAD 

121 Santa Ana(J.Wayne) CA USA SNA California (CA) USA 146 Wausau(Central) WI USA CWA 122 Santa Barbara CA USA SBA California (CA) USA 147 West Palm Beach(Intl) FL USA PBI 

123 Santa Fe NM USA SAF New Mexico (NM) USA 148 Westchester County NY USA HPN 

124 Savannah/Hilton Head GA USA SAV Georgia (GA) USA 149 Wichita Falls TX USA SPS 

SOURCE: OAG , December 2009

125 Seattle/Tacoma(Intl) WA USA SEA Washington (WA) USA 150 Wichita KS USA ICT 
Linking JAL’s Unique Asia Airports With Unique International Airp

Served By American Will Add 15 080 New Global Immunized AirporServed By American Will Add 15,080 New Global Immunized Airpor

International Airports At Which American (But Not JAL) Operates

# Name Airport Code Country # Name Airport Code Count1 Acapulco Mexico ACA Mexico 26 George Town Bahamas GGT Baham

2 Aguascalientes Mexico AGU Mexico 27 Governors Harbour Bahamas GHB Baham

Grand Cayman Is. West

3 Anguilla Leeward Is. AXA Anguilla West Indies 28

y

Indies GCM Cayma

4 Antigua West Indies ANU Antigua/Barbuda West Indies 29

Grenada (M. Bishop)

Windward Is. GND

GrenaIsland

5 Aruba AUA Aruba 30 Guadalajara Mexico GDL Mexic6 Barbados BGI Barbados 31 Guatemala City Guatemala GUA Guate

7 Barcelona Spain BCN Spain

& Canary Islands 32 Guayaquil Ecuador GYE Ecuad

8 Belize City(Intl) City(Intl) Belize BZE Belize 33 Halifax(Intl) Halifax(Intl) NS Canada YHZ Nova S9

Belo Horizonte (Tancredo

Neves) Brazil CNF Brazil 34 Ixtapa/Zihuatanejo Mexico ZIH Mexic

10 Bermuda (Wade Intl) Bermuda BDA Bermuda 35 Kingston(Intl) Jamaica KIN Jamaic

11 Bogota Colombia BOG Colombia 36 La Paz Bolivia LPB Bolivia

12 Brussels Belgium BRU Belgium 37 Leon/Guanajuato Mexico BJX Mexic

13

Buenos Aires(Pistarini) BA

13 A ti rgen na EZE A ti rgen na 38 Lib i er a C t os a Rica LIR C t os a 

14 Calgary AB Canada YYC Alberta (AB) Canada 39 Lima Peru LIM Peru15 Cali Colombia CLO Colombia 40 Los Cabos Mexico SJD Mexic

16 Cancun Mexico CUN Mexico 41 Madrid Spain MAD Spain

17 Caracas Venezuela CCS Venezuela 42 Managua Nicaragua MGA Nicara

18 Casa De Campo Dominican Rep. LRM Dominican Republic 43 Manchester England UK MAN United 

19 Chih h ua ua M i ex co CUU M i ex co 44 M ib aracaibo V l enezuela MAR V 

enez

20 Cozumel Mexico CZM Mexico 45 Marsh Harbour Bahamas MHH Baham

21 Curacao Neth. Antilles CUR Netherland Antilles 46 Medellin(Cordova) Colombia MDE Colom

22 Dominica West Indies DOM Dominica West Indies 47 Montego Bay Jamaica MBJ Jamaic

23 Dublin Ireland DUB Ireland 48 Monterrey Mexico MTY Mexic

24 Freeport Bahamas FPO Bahamas 49 Montevideo Uruguay MVD Urugu

SOURCE: OAG , December 2009

25 Ft. De France Martinique FDF Martinique 50 Montreal(P.E. Trudeau) YUL Quebe
Linking JAL’s Unique Asia Airports With Unique International Airp

Served By American Will Add 15 080 New Global Immunized AirporServed By American Will Add 15,080 New Global Immunized Airpor

International Airports At Which American (But Not JAL) Operates

# Name Airport Code Country # Name Airport Code Country

51 Nassau(Intl) Bahamas NAS Bahamas 76

St. Maarten(P.Juliana) Neth.

( ) Antilles SXM Netherla

52 North Eleuthera Bahamas ELH Bahamas 77 Tegucigalpa Honduras TGU Hondura53 Ottawa ON Canada YOW Ontario (ON) Canada 78 Toronto(Pearson Intl) ON YYZ Ontario 

54 Panama City(Intl) Panama PTY Panama 79 Torreon Mexico TRC Mexico55 Pointe A Pitre Guadeloupe PTP Guadeloupe 80 Tortola/Beef Is. BVI EIS British V

56 Providenciales Turks

& Caicos Is. PLS Turks

& Caicos Islands 81 Treasure Cay Bahamas TCB Bahama

57 Pt. Au Prince Haiti PAP Haiti 82 Zurich Switzerland ZRH Switzerl

58 Pt. of Spain Trinidad POS Trinidad

& Tobago

59 Puerto Plata Dominican Rep. POP Dominican Republic

60 Puerto Vallarta Mexico PVR Mexico

61 Punta Cana Dominican Rep. PUJ Dominican Republic

62 Quito Ecuador UIO Ecuador

63 Rio De Janeiro(Intl) RJ Brazil GIG Brazil

64 Salvador BA Brazil SSA Brazil65 San Jose(Santamaria) Costa Rica SJO Costa Rica66 San Luis Potosi Mexico SLP Mexico

67 San Pedro Sula Honduras Honduras SAP Honduras Honduras68 San Salvador El Salvador SAL El Salvador

69 Santa Cruz(Intl) Bolivia VVI Bolivia

70 Santiago Dominican Rep. STI Dominican Republic

71 Santiago(Intl) Chile SCL Chile72 Santo Domingo Dominican Rep. SDQ Dominican Republic

SOURCE: OAG , December 2009; MIDT, Year 2009

73 St. Kitts Leeward Is. SKB St. Kitts/Nevis Leeward Islands

74 St. Lucia(Hewanorra) UVF St. Lucia West Indies

75 St. Lucia(Vigie) West Indies SLU St. Lucia West Indies
The American/JAL Immunized Alliance Will Add 65 N

A

s a po ts o e u ed o e ia Airpo

rts To Th

e Imm

unized

o

n

e

w

o drl

d

G oba et 

lobal Net

w

SOURCE: OAG, December 2009
The American/JAL Immunized Alliance Will Add 65 N

A

s a po ts o e u ed o e ia Airpo

rts To Th

e Imm

unized

o

n

e

w

o drl

d

G oba et 

lobal Net

w

AKJ – Asahikawa JapanAOJ – Aomori JapanASJ – Amami O Shima JapanAXT – Akita JapanBKK Bangkok (Intl) Thailand

KUL – Kuala Lumpur (Intl) MalaysiaMMB – Memanbetsu JapanMMY – Miyako Jima JapanMNL – Manila Philippines

BKK

– Bangkok (Intl) Thailand MSJ Misawa Japan

CAN – Guangzhou ChinaCTS – Sapporo (Chitose) JapanDLC – Dalian ChinaFSZ – Shizuoka JapanFUK – Fukuoka JapanGAJ 

– Yamagata Ja

pan

MSJ

– Misawa Japan

MYJ – Matsuyama Shikoku JapanNGO – Nagoya (Intl) JapanNGS – Nagasaki JapanNKM – Nagoya (Komaki) JapanOBO – Obihiro Japan

g p OGN 

– Yonaguni Jima Ja

pan

GMP – Seoul (Gimpo Intl) Rep. of KoreaHAN – Hanoi VietnamHGH – Hangzhou ChinaHIJ – Hiroshima (Intl) ChinaHKD – Hakodate JapanHNA – Hanamaki JapanHND Tk (H d ) J

g p

OIT – Oita JapanOKA – Okinawa JapanOKJ – Okayama JapanPEK – Beijing (Capital) ChinaPUS – Busan Rep. of KoreaPVG – Shanghai (Pu Dong Intl) China

HND

–

Tokyo (Hane

da) Japan SDJ S d iJ

ICN – Seoul (Incheon Intl) Rep. of Korea ISG – Ishigaki JapanITM – Osaka (Itami) JapanIZO – Izumo JapanKCZ – Kochi JapanKHH 

– Kaohsiung Chinese Tai

pei

SDJ

– Sen

dai Japan

SGN – Ho Chi Minh City VietnamSHA – Shanghai (Hongqiao Intl) ChinaSHM – Nanki Shirahama JapanSIN – Singapore (Changi)TAK – Takamatsu Japan

g p TAO

– Qingdao China

KIJ – Niigata JapanKIX – Osaka (Kansai Intl) JapanKKJ – Kita Kyushu JapanKMI – Miyazaki JapanKMJ – Kumamoto JapanKMQ – Komatsu Japan

O hi

TAO Qingdao ChinaTKN – Tokunoshima JapanTKS – Tokushima JapanTPE – Taipei (Taoyuan Intl) Chinese TaipeiTSN – Tianjin ChinaUBJ – Ube Japan

SOURCE: OAG, December 2009

K

OJ – Kagoshima Japan

KUH – Kushiro Japan

UEO 

– Kume Jima Japan

UKB – Osaka (Kobe) JapanXMN – Xiamen China
The Scope Of The Proposed Joint Venture Will Cover 15 745 TranspaThe Scope Of The Proposed Joint Venture Will Cover 15,745 Transpa

Airport Pairs And Approximately 17.1 Million Annual Passengers

Caribbean/North/South Pacific Joint Ventu

America Airports Asia Airports Pacific Joint Ventu

Airport Pairs

235 X 67 = 15,745

The Scope Of The Pacific Joint Venture (Asia Airports To/F

Caribbean/North/South America Airports) Accounts For ApproxCaribbean/North/South America Airports) Accounts For Approx

17.1 Million Annual Passengers

SOURCE: OAG, December 2009; MIDT, Year 2009
A G t Of ATI T Th A i /JAL Alli Will N A

Gran

t Of ATI

To The 

American/JAL Alliance Will

N

Reduce The Intense Competition In The U.S.-Asia Ma

• 21 carriers including four U S network carriers 21 carriers, including four

U.S. network carriers, 

operate nonstop scheduled service between 18 U.S. points and 19 Asia points

• Delta/Northwest/Korean will continue to hold the largest Delta/Northwest/Korean will continue to hold the largest

share (25.8% of nonstop seats)

• American/JAL’s share will be 20.1% of nonstop seats

SOURCE: OAG, December 2009
A Grant Of ATI To The American/JAL Alliance Will N

R d Th I t C titi I Th U S Ai M 

U.S. To Asia Seat Shares U.S. To/From Asia BookingsAirline Code Airline Name Daily Seats % Share Airline Code Airline Name JL/JO J Ai li 6 219 16 3% DL/NW D lt /N th t 2 

R

e

duce The In

tense 

Competition In The 

U.S.-

A

sia 

Ma

JL/JO Japan Airlines 6,219 16.3% DL/NW Delta/Northwest 2,DL/NW Delta/Northwest 5,534 14.5% UA United Airlines 2,

KE Korean Air 4,299 11.3% JL/JO Japan Airlines 1,

UA United Airlines 4,009 10.5% KE Korean Air 1,

CO Continental Airlines Continental Airlines 2 976 , 7 8%. CX Cathay Pacific Pacific Airways Airways CX Cathay Pacific Airways 2,306 6.1% OZ Asiana Airlines 

NH All Nippon Airways 2,201 5.8% BR EVA Airways 

OZ Asiana Airlines 2,016 5.3% NH All Nippon Airways CI China Airlines Airlines 1,905 5.0% AA American American Airlines Airlines BR EVA Airways 1,628 4.3% CI China Airlines AA American Airlines 1,442 3.8% PR Philippine Airlines SQ Singapore Airlines 1,060 2.8% CO Continental Airlines 

CA Air China 832 2.2% CA Air China 

MU China Eastern Airlines 484 1.3% SQ Singapore Airlines PR Philippine Airlines 231 0.6% MU China Eastern Airlines 

TG Thai Airways Intl 215 0.6% HA Hawaiian Airlines CZ China Southern Airlines 202 0.5% Other 

SOURCE: OAG, December 2009; MIDT, Year 2009

Other 539 1.4% Total 14,

Total 38,097 100%
Passengers Traveling on American/Japan Airlines Nonstop Ov

Continue to Benefit From Significant Nonstop (And Other) CoContinue to Benefit From Significant Nonstop (And Other) Co

Nonstop Largest

Overlap 

Route

Service

Before / After

MIDT

Bookings

AA/JL

Share

Nonstop

Competitor

Book

Sha

NYC-NRT 5 to 4 356,860 45.0% NH 22.0

LAX-NRT 7 to 6 467,454 20.3% KE 21.7

ORD-NRT 4 to 3 99,231 44.2% UA 25.2
Overlap City Pair Analysis

O e ap C ty a a ys s

Chicago - Tokyo (4 to 3) New York - Tokyo (5 

Airline Code Route Seat Share Booking Share

JL ORD-NRT 33.3% 28.5%

NH ORD-NRT 25.4% 24.5%

UA ORD-NRT 24.9% 25.2%

AA ORD-NRT 16.4% 15.7%

Airline Code Route Seat Sh

JL NYC-NRT 35.3% 

NH NYC-NRT 19.9% 

DL-NW NYC-NRT 17.2% 

CO NYC-NRT 14.8% 

AA NYC NRT 12 9% 

TOTAL

10,521 seats

per week

99,231 annual

bookings

AA NYC-NRT 12.9% 

TOTAL

12,266 s

per we

Los Angeles - Tokyo (7 to 6)

Airline Code Route Seat Share Booking Share

JL LAX-NRT 19.6% 13.5%

NH LAX-NRT 15.0% 14.5%

SQ LAX-NRT 14.7% 20.4%

DL-NW LAX-NRT 15.7% 12.5%

UA LAX-NRT 13.6% 9.6%

KE LAX-NRT 11.8% 21.7%

AA LAX-NRT 9.7% 6.8%

TOTAL

19,924 seats

per week

467,454 annual

bookings
Joint Applicants’ U.S. To International Ro

# Airline Name Market

Weekly

Frequencies # Airline Name Market

Fre

1 American Airlines ACA-DFW 2 40 American Airlines DFW-EZE 2 American Airlines AGU-DFW 7 41 American Airlines DFW-FRA 3 American Airlines ANU-MIA 6 42 American Airlines DFW-GDL 4 American Airlines AUA-BOS 2 43 American Airlines DFW-GRU 5 American Airlines AUA-JFK 3 44 American Airlines DFW-GUA 6 American Airlines AUA-MIA 14 45 American Airlines DFW-LHR 7 American Airlines BCN-JFK 7 46 American Airlines DFW-LIR 8 American Airlines BDA-JFK 7 47 American Airlines DFW-MAD 9 American Airlines BDA-MIA 7 48 American Airlines DFW-MBJ 

10 American Airlines BGI-JFK 7 49 American Airlines DFW-MEX 11 American Airlines BGI-MIA 14 50 American Airlines DFW-MTY 

12 American Airlines BJX-DFW 21 51 American Airlines DFW-NAS 13 American Airlines BOG-MIA 14 52 American Airlines DFW-NRT 14 American Airlines BOS-CDG 5 53 American Airlines DFW-PLS 15 American Airlines BOS-LHR 17 54 American Airlines DFW-PTY 16 American Airlines BOS-SDQ 1 55 American Airlines DFW-PVR 17 American Airlines BOS-YYZ 25 56 American Airlines DFW-SAL 18 American Airlines BRU-JFK 7 57 American Airlines DFW-SCL 19 American Airlines American Airlines BRU-ORD BRU-ORD 7 58 American Airlines American Airlines DFW-SJD DFW-SJD 20 American Airlines BZE-DFW 7 59 American Airlines DFW-SJO 21 American Airlines BZE-MIA 14 60 American Airlines DFW-SLP 22 American Airlines CCS-DFW 1 61 American Airlines DFW-TRC 23 American Airlines CCS-JFK 2 62 American Airlines DFW-YUL 24 American Airlines CCS-MIA 28 63 American Airlines DFW-YVR 25 American Airlines CCS-SJU 7 64 American Airlines DFW-YYC 26 American Airlines CDG-DFW 7 65 American Airlines DFW-YYZ 27 American Airlines CDG-JFK 14 66 American Airlines DFW-ZIH 28 American Airlines CDG-MIA 7 67 American Airlines DUB-ORD 29 American Airlines CDG-ORD 7 68 American Airlines EZE-JFK 30 American Airlines CLO-MIA 7 69 American Airlines EZE-MIA 31 American Airlines CNF-MIA 3 70 American Airlines FCO-JFK 32 American Airlines CUN-DFW 28 71 American Airlines FCO-ORD 33 American Airlines CUN-JFK 9 72 American Airlines FLL-PAP 34 American Airlines American Airlines CUN MIA CUN-MIA 29 73 American Airlines American Airlines FLL SJO FLL-SJO 35 American Airlines CUN-ORD 7 74 American Airlines FRA-ORD 36 American Airlines CUR-MIA 14 75 American Airlines GCM-MIA 37 American Airlines CUU-DFW 14 76 American Airlines GIG-MIA 38 American Airlines CZM-DFW 7 77 American Airlines GND-MIA 39 American Airlines DEL-ORD 7 78 American Airlines GRU-JFK 
Joint Applicants’ U.S. To International Ro

# Airline Name Market

Weekly

Frequencies # Airline Name Market

Fre

79 American Airlines GRU-MIA 22 118 American Airlines MAR-MIA 80 American Airlines GUA-MIA 21 119 American Airlines MBJ-MIA 

81 American Airlines GYE-MIA 9 120 American Airlines MBJ-ORD 

82 American Airlines JFK-LHR 32 121 American Airlines MDE-MIA 

83 American Airlines JFK-MAD 5 122 American Airlines MEX-MIA 84 American Airlines JFK-MAN 3 123 American Airlines MGA-MIA 85 American Airlines JFK-MBJ 5 124 American Airlines MIA-MVD 

86 American Airlines JFK-MXP 6 125 American Airlines MIA-NAS 

87 American Airlines JFK-NRT 7 126 American Airlines MIA-PAP 

88 American Airlines JFK-PAP 7 127 American Airlines MIA-PLS 

89 American Airlines JFK-PLS 7 128 American Airlines MIA-POP 

90 A i Ai li American Airlines JFK PUJ JFK-PUJ 7 129 A i Ai li American Airlines MIA POS MIA-POS 91 American Airlines JFK-SDQ 11 130 American Airlines MIA-PTY 92 American Airlines JFK-SJO 4 131 American Airlines MIA-PUJ 

93 American Airlines JFK-SKB 2 132 American Airlines MIA-SAL 

94 American Airlines JFK-STI 7 133 American Airlines MIA-SAP 

95 American Airlines JFK-SXM 3 134 American Airlines MIA-SCL 

96 American Airlines JFK-UVF 2 135 American Airlines MIA-SDQ 

97 American Airlines American Airlines JFK YHZ - 14 136 American Airlines American Airlines MIA SJO - 98 American Airlines JFK-YUL 21 137 American Airlines MIA-SKB 

99 American Airlines JFK-YYZ 21 138 American Airlines MIA-SSA 

100 American Airlines JFK-ZRH 7 139 American Airlines MIA-STI 101 American Airlines KIN-MIA 22 140 American Airlines MIA-SXM 

102 American Airlines LAX-LHR 7 141 American Airlines MIA-TGU 103 American Airlines LAX-NRT 7 142 American Airlines MIA-UIO 

104 American Airlines LAX-SAL 7 143 American Airlines MIA-UVF 

105 American Airlines LAX-SJD 14 144 American Airlines MIA-YUL 

106 American Airlines LAX-YYZ 7 145 American Airlines MIA-YYZ 

107 American Airlines LGA-YUL 27 146 American Airlines NRT-ORD 

108 American Airlines LGA-YYZ 81 147 American Airlines ORD-PEK 109 American Airlines LHR-MIA 9 148 American Airlines ORD-PVG 110 American Airlines LHR-ORD 25 149 American Airlines ORD-PVR 111 American Airlines LHR-RDU 7 150 American Airlines ORD-SJD 

112 American Airlines American Airlines LIM MIA LIM-MIA 20 151 American Airlines American Airlines ORD YOW ORD-YOW 113 American Airlines LIR-MIA 8 152 American Airlines ORD-YUL 

114 American Airlines LPB-MIA 8 153 American Airlines ORD-YVR 

115 American Airlines LRM-MIA 2 154 American Airlines ORD-YYC 

116 American Airlines MAD-MIA 7 155 American Airlines ORD-YYZ 

117 American Airlines MAN-ORD 7 156 American Airlines SDQ-SJU 
Joint Applicants’ U.S. To International Ro

# Airline Name Market

Weekly

Frequencies

1 Japan Airlines 1/ 1 Japan Airlines GUM-NRT 142 Japan Airlines 1/ GUM-KIX

7

3 Japan Airlines 1/ HNL-NGO

7

4 Japan Airlines 1/ HNL-NRT 27

5 Japan Airlines 1/ HNL-KIX

7

6 Japan Airlines JFK-NRT

9

7 Japan Airlines GRU-JFK

2

8 Japan Airlines LAX-NRT

7

9 Japan Airlines NRT-ORD

7

10 Japan Airlines NRT-SFO

7

1/ Operated by JALways,

a wholly owned JAL subsidiary
Joint Applicants’ International Codeshare P

Jo t pp ca ts te at o a Codes a e 

Alaska Airlines AS Air France AF 

British Airways BA Air New Zealand NZ 

Br ssels Airlines SN Air Tahiti N i TN

American Airlines (AA) Japan Airlines (JL, JO, JC, NU)

Brussels Airlines SN Air Tahiti Nui TN

Cathay Pacific Airways CX Alitalia AZ China Eastern Airlines MU American Airlines AA Click Grupo Mexicana QA American Eagle MQ 

El Al Israel Airlines LY British Airways BA 

Etihad Airways Etihad Airways EY Cathay Pacific Airways Cathay Pacific Airways CX

EVA Airways BR China Eastern Airlines MU Finnair AY China Southern Airlines CZ Gulf Air GF Emirates Airlines EK 

Horizon Air QX Finnair AY 

Iberia IB Iberia IB

JAL Express JC Jetstar Airways JQ 

Japan Airlines JL Korean Air KE 

Jet Airways India Ltd 9W MALEV Hungarian Airlines MA Jetconnect A507 Mexicana De Aviacion MX Lan Airlines LA Q y antas Airways QF 

LAN Argentina 4M Thai Airways Intl TG Lan Express LU Vietnam Airlines VN 

Lan Peru LPMALEV Hungarian Airlines MAMexicana De Aviacion MX

Sou

Qantas Airways QFRoyal Jordanian RJVietnam Airlines VN
Carriers operating Scheduled Internatio

Services at American’s Hubs and Gateway 

Dallas-Fort Worth (DFW) Miami (MIA) New York (JFK) Los Angeles (LAX) 

Air Canada Aerogal Aer Lingus Aeroflot Russian Airlines 

Air Canada Jazz Aerolineas Argentinas Aeroflot Russian Airlines Aeromexico 

American Airlines Aeromexico Aerogal Aeromexico Connect 

American Eagle Aeromexico Connect Aeromexico Air Canada 

British Airways Aerosur Aerosvit Airlines Air Canada Jazz 

KLM-Royal Dutch Airlines Air Berlin Air China Air China 

Korean Air Air Canada Air Dominicana Air France 

LACSA Air Dominicana Air Dominicana Air Europa Air Europa Air New Zealand Air New Zealand 

Lufthansa Air Europa Air France Air Pacific 

Mexicana De Aviacion Air France Air India Air Tahiti Nui 

Sun Country Airlines Alitalia-Compagnia Aerea Air Jamaica Alaska Airlines 

Taca Intl Airlines American Airlines Alitalia-Compagnia Aerea Alitalia-Compagnia Aerea 

American Eagle All Nippon Airways All Nippon Airways 

American Eagle/Executive American Eagle/Executive American Airlines American Airlines American Airlines American Airlines 

Avianca American Eagle Asiana Airlines 

Avior Airlines Asiana Airlines Avianca 

Bahamasair Austrian Airlines British Airways 

British Airways Avianca Cathay Pacific Airways 

Caribbean Airlines British Airways China Airlines 

Cayman Airways Caribbean Airlines China Eastern Airlines 

Copa Airlines Cathay Pacific Airways China Southern Airlines 

Corsair Intl Cayman Airways Copa Airlines 

Finnair China Eastern Airlines Delta Air Lines 

Gulfstream Intl Airline Comair Inc. El Al Israel Airlines 

Iberia Copa Airlines Emirates Airlines 

Insel Air Delta Air Lines EVA Airways 

LACSA E ti gyp

air H i Ai or zon Air 

Lan Airlines El Al Israel Airlines Japan Airlines S

LAN Argentina Emirates Airlines KLM-Royal Dutch Airlines 

Lan Peru Etihad Airways Korean Air 

LanEcuador Eurofly LACSA 
Carriers operating Scheduled Internatio

p g

Services at American’s Hubs and Gateway 

Miami (MIA) New York (JFK) Los Angeles (LAX) 

LTU International Airways Finnair Lan Airlines 

Lufthansa Iberia Lan Peru 

Mexicana De Aviacion Icelandair LTU International Airways 

Santa Barbara Airlines Japan Airlines Lufthansa 

Surinam Airways Jet Airways India Ltd Malaysia Airlines 

SWISS jetBlue Airways Mexicana De Aviacion 

Taca Intl Airlines KLM-Royal Dutch Airlines Northwest Airlines

TACA Peru K Ai orean Air Q t Ai an as Airways

TAM Linhas Aereas Kuwait Airways Singapore Airlines

Virgin Atlantic Airways LACSA SWISS

WestJet Lan Airlines Taca Intl Airlines

LanEcuador Thai Airways Intl

LOT Polish Airlines UA EXP/Skywest

LTU International Airways LTU International Airways United Airlines United Airlines

Lufthansa Vaustralia

Mexicana De Aviacion Virgin Atlantic Airways

OpenSkies Volaris

Pakistan Intl Airline WestJet

Qatar Airways

Royal Air Maroc

Royal Jordanian

Saudi Arabian Airlines

Singapore Airlines

South African Airways

SWISS

Taca Intl Airlines

TAM Linhas Aereas

Turkish Airlines

Uzbekistan Airways

Virgin Atlantic Airways

XL Airways France
The Joint Applicants’ U.S. To Asia Nonstop 

e Jo t pp ca ts U S o s a o stop 

Airport Pair

Weekly 

Frequencies

DFWNRT 14

American Airlines (AA)

Airport Pairs

Weekly

Frequencies

GUMKIX** 7

Japan Airlines (JL JO)

JFKNRT 7LAXNRT 7

NRTORD 7

ORDPEK* 5

ORDPVG 7

GUMNRT** 14

HNLKIX** 7

HNLNGO** 7HNLNRT** 27

JFKNRT 9

* Effective 04/26/2010 * * Operated by JALways, a wholly owned JAL 

LAXNRT 7

NRTORD 7

NRTSFO 7
CERTIFICATE OF SERVICE

 

 I hereby certify that I have this day served the foregoing 

document by email on the following persons: 

 

sascha.vanderbellen@delta.com jhill@dlalaw.com 

scott.mcclain@delta.com bill@mietuslaw.com 

sametta.c.barnett@delta.com mgoldman@sgbdc.com 

kquinn@pillsburywinthrop.com rsilverberg@sgbdc.com 

bkeiner@crowell.com dhainbach@ggh-airlaw.com 

mrosia@crowell.com mcmillin@woa.com 

bruce.rabinovitz@wilmerhale.com mchopra@jamhoff.com 

jeffrey.manley@united.com russell.bailey@alpa.org 

bob.kneisley@wnco.com dkirstein@yklaw.com 

robert.land@jetblue.com jyoung@yklaw.com 

msinick@ssd.com donna.kooperstein@usdoj.gov 

cdonley@ssd.com dwight.moore@ustranscom.mil 

anbird@fedex.com jim.ballough@faa.gov 

dvaughan@kelleydrye.com byerlyjr@state.gov 

kevin.montgomery@polaraircargo.com recohn@hhlaw.com 

jrichardson@johnlrichardson.com cjsimpson@zsrlaw.com 

lhalloway@crowell.com pmurphy@lopmurphy.com 

efaberman@wileyrein.com lachter@starpower.net 

mroller@rollerbauer.com anita.mosner@hklaw.com 

howard.kass@usairways.com rpommer@atlasair.com 

benjamin.slocum@usairways.com gmurphy@crowell.com 

sophy.chen@hklaw.com 

 

 ____________________________ 

 JEFFREY A. OGAR 

February 12, 2010