BEFORE THE 

U.S DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, DC 

Cf RTKIIOH 

Application of 

INTERNATIONAL JET 

MANAGEMENT GMBH Docket DOT-OST- 2010-6^3' ^ 

For Exemption Authority Pursuant to 

49 UCS 40109 for Foreign Air Carrier Permit 

MOTION FOR CONFIDENTIAL TREATMENT PURSUANT TO RULE 12 

Communications with respect to this document should be sent to: 

Felix Feller 

President 

International Jet Management GmbH 

Concorde Business Park2/F14 

2320 Schwechat 

Republic of Austria 

Voice: 43 1 707 82 50-10 

Fax: 43 1 707 82 50-90 

Email : s .diemt@iim . • a t 

Richard A. Asper, J.D., Chairman 

C.A. Southerland, Vice President 

Aviation Professionals Group, Inc. 

3000 NE 30"^ Place, Suite 107 

Fort Lauderdale, FL 33306 

Voice: (954) 763-4848 

Fax: (954) 763-4240 

Email: 

ca@aviation-professionals.com 

ricRaiJaviati on-professionals . com 

Representatives for 

International Jet Management GmbH 

Filed on February 18, 2010 
BEFORE THE 

U.S DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, DC 

Docket DOT-OST-2010-

Application of 

INTERNATIONAL JET 

MANAGEMENT GMBH 

For Exemption Authority Pursuant to 

49 UCS 40109 for Foreign Air Carrier Permit 

MOTION FOR CONFIDENTIAL TREATMENT PURSUANT TO RULE 12 

International Jet Management GmbH ("IJM" or "Applicant") hereby moves for confidential 

treatment of Exhibit 13 (Financial Information) to its Application in this Docket pursuant to Rule 12 of 

the Department's Rules of Practice (14 C.F.R. § 302.12). The confidential information has been filed 

under seal and with the marking "Confidential Treatment Requested Under 14 C.F.R. § 302.12", as 

provided in 14 C.F.R. §302.12. Approval of Applicant's request for confidential treatment would be 

consistent with the Department's Rules and the Freedom of Information Act (5 U.S.C. § 552(b)(4)), its 

precedents and the Freedom of Information Act (5 U.S.C. 552(b)(4). The filing contains commercially 

sensitive information that, if released publicly, could cause substantial competitive harm to IJM. This 

information would not otherwise be disclosed to the public by IJM. 

To be withheld from public disclosure under Rule 12, documents must contain information that 

is (1) commercial or financial; (2) obtained from a person outside of government; and (3) privileged or 

confidential. The information for which confidentiality is requested clearly satisfies requirements one 

and two, in that it consists of commercially-sensitive and confidential information of IJM that was 

obtained directly from IJM. It also clearly satisfies the third requirement as well, as this is the type of 

information that has been considered confidential by the Department in the past. 

Additionally, release of this financial information would cause substantial harm to the 

competitive position of IJM and would impair the goverimient's ability to collect such information in the 

future. Should this information be made public, it could permit competitors of IJM to gain insights into 

the company, its operating plans and its funding that could be used by them to undermine its service. 

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resulting in great economic harm to IJM, its investors and competition. 

Furthermore, the information may properly be withheld from public disclosure under Exemption 

4 of the Freedom of Information Act, 5 U.S.C. § 552(b)(4), which permits protection fi"om disclosure for 

"trade secrets and commercial or financial information obtained from a person and privileged or 

confidential." See, e.g., Gulf& Western Industries, Inc. v. United States, 615 F.2d 527 (D.C. Cir. 1979); 

Critical Mass Energy Project v. NRC, 975 F.2d 871 (D.C. Cir.1992). The Freedom of Information Act, 5 

U.S.C. § 552(b)(4), provides that privileged or confidential commercial and financial Information 

obtained from a private person is specifically exempt from the requirements of public disclosure due to 

its business-sensitive nature. The Information for which this motion requests confidential treatment is 

confidential and proprietary commercial and financial information of a private party and the public 

release of this information would cause competitive and financial injury to that party. Accordingly, the 

information should be withheld from public disclosure. 

WHEREFORE, INTERNATIONAL JET MANAGEMENT GMBH respectfully moves that the 

attached Exhibit 13, submitted under seal with this motion, be withheld from public disclosure for a 

period often (10) years, pursuant to Rule 12 of the Department's Rules of Practice in Proceedings. 

Respectfully submitted. 

Aviation Professionals Group, Inc., for 

INTERNATIONAL JET MANAGEMENT GMBH 

C.A. Southerland 

Voice (954)763-4848 

Email:ca@aviation-professionals.com 

Representatives for 

International Jet Management GmbH 

Date: February 18,2010 

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