American Airlines Inc v. Travelport Limited et al

Filing 45

Appendix in Support filed by Sabre Inc, Sabre Travel International Ltd re #43 MOTION to Intervene as Defendants, #44 Brief/Memorandum in Support of Motion (Attachments: #1 Exhibit(s) A - Proposed Complaint Against American Airlines, #2 Exhibit(s) B - Gilliland Declaration in Support of Motion to Intervene, #3 Exhibit(s) C - Stand Down Agreement (1-12-11)) (Fredricks, Scott)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
AMERICAN AIRLINES, INC.,

)
)
Plaintiff
)
)
vs.
)
)
TRAVELPORT LTD; TRAVELPORT, )
LP; TRAVELPORT; and ORBITZ
)
WORLDWIDE, LLC
)
)
Defendants
)
)
SABRE INC. AND SABRE TRAVEL )
INTERNATIONAL LTD,
)
)
Plaintiffs
)
)
vs.
)
)
AMERICAN AIRLINES, INC.
)
)
Defendant
)

Civ. No. 4:11-cv-00244-Y
JURY TRIAL DEMANDED

COMPLAINT
Plaintiffs Sabre Inc. and Sabre Travel International Ltd. (collectively “Sabre”), in support
of their Complaint against defendant American Airlines, Inc. (“AA”), state as follows:

INTRODUCTION
1.

This is an antitrust action against AA for damages and injunctive relief to stop

AA’s anticompetitive campaign to gouge the consuming public by destroying independent
computer reservation systems, including Sabre, and making it more difficult for travel agents,
corporate travel purchasers and consumers to comparison shop for the lowest available fares,
thereby suppressing airline competition.

App. 5

2.

AA is one of the world’s largest airlines and is a monopolist on most routes into

and out of at Dallas/Fort Worth International (“DFW”) and Miami International (“MIA”) airports
with more than 70%—and, on many routes 100%—share of flights and seats. AA also
dominates flights between the United States and destinations in the Caribbean and has a
significant share of flights into and out of Chicago’s O’Hare Airport (“ORD”).
3.

Sabre operates a global distribution system, or “GDS” (the “Sabre GDS”). A

GDS is a sophisticated computerized reservation system (“CRS”) used by travel agents,
corporate travel purchasers and on-line consumers to shop for and book flights and other travel
products, such as hotels. Other GDSs include the Galileo and Worldspan systems operated by
Travelport and the Amadeus system.
4.

GDSs compile data such as fare information, flight times, and routes from

hundreds of airlines around the world into one computerized system for the benefit of travel
agents and their customers as part of the comprehensive data services they provide. A critical
part of the value proposition of the GDSs is to empower travel agents, corporate travel
purchasers and consumers that use on-line travel agency services to comparison shop more than
400 competing airlines’ pricing, flight times, and other information efficiently and quickly. This
is unlike the reservation services of individual airlines, which provide information about only the
individual airlines’ own flights.
5.

Side-by-side comparison promotes competition among airlines and drives down

prices. While this price transparency benefits consumers, AA does not like it because it reduces
its ability to charge monopoly prices and to avoid competition from other airlines.
6.

AA has therefore embarked on an anticompetitive campaign to destroy Sabre (and

the other GDSs, including the GDSs operated by Travelport) and the price transparency and

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App. 6

competition they facilitate by, among other things: (1) refusing to provide its fare information to
GDSs, (2) inviting other airlines to do the same, and (3) bullying and raising costs to travel
agents who are dependent on AA for their livelihood, and corporate travel purchasers who are
tasked with obtaining the best overall value for their companies in air transport markets
frequently dominated by AA, to book through AA’s own proprietary product called AA Direct
Connect in order to obtain AA’s fare information.
7.

This antitrust lawsuit is brought to stop AA’s anticompetitive scheme and the

harm it has caused and will cause to Sabre, to protect competition in the market for airline
services, and to preserve the competitive market for booking airline transportation that has
brought airline prices down for the traveling public.

THE PARTIES
8.

Plaintiff Sabre, Inc. is a Delaware corporation with its principal place of business

and headquarters at 3150 Sabre Drive, Southlake, Texas 76092. Sabre, Inc. owns the on-line
travel agency Travelocity.
9.

Plaintiff Sabre Travel International Ltd. is an Irish corporation with its principal

place of business at 3150 Sabre Drive, Southlake, Texas 76092.
10.

Defendant AA is a Delaware corporation with its principal place of business and

headquarters at 4333 Amon Carter Blvd, Fort Worth, Texas 76155.

JURISDICTION AND VENUE
11.

This is a federal antitrust action for damages and injunctive relief arising out of

the unlawful and anticompetitive conduct of AA. It arises under Sections 1 and 2 of the Sherman
Antitrust Act, 15 U.S.C. §§ 1, 2 and Sections 4 and 6 of the Clayton Antitrust Act, 15 U.S.C. §§
15, 26.

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App. 7

12.

AA is engaged in interstate commerce and in activities that substantially affect

interstate commerce.
13.

Subject matter jurisdiction over the federal antitrust claims is proper in this Court

under 28 U.S.C. §§ 1331, 1337(a) and 15 U.S.C. § 4.
14.

The Court has general and specific personal jurisdiction over defendant AA

because AA conducts substantial business in this district, regularly solicits business from, does
business with, and derives value from goods and services provided to customers in this judicial
district, and has committed, or intends imminently to commit, acts in violation of the federal
antitrust laws in this judicial district, and such acts are and will be continuing. AA has also
availed itself of the jurisdiction of this Court by bringing suit against, among others, Travelport.
15.

Venue is proper in this judicial district and division pursuant to 28 U.S.C.

§§ 1391(b), (c) and 15 U.S.C. § 22 because AA resides in this judicial district and division, has
committed, or intends imminently to commit, acts in violation of the federal antitrust laws in this
judicial district and division, transacts a substantial amount of business within this judicial
district and division, and is subject to personal jurisdiction in this judicial district and division.

AA’S ANTICOMPETITIVE CONDUCT
16.

Through a variety of means, including ultimately eliminating GDSs like Sabre,

AA seeks to destroy the ability of travel agents, corporate travel purchasers, and the traveling
public to make apple-to-apple price comparisons.
17.

AA does not like the competition that GDSs enable. To eliminate this

competition and the ability of travel agents, corporate travel purchasers and consumers to make
direct fare comparisons between AA and its competitor airlines, AA has chosen to discontinue its
decades-long and profitable practice of providing its full flight and fare information (“Complete

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App. 8

Fare Information”) for use on Sabre’s GDS. It refuses to provide information about ancillary
fares—fares charged on top of a ticket’s base fare—that AA now charges for services that it
previously included in the base fare, such as the ability to check baggage (“Add-On Fares”). AA
has stated its intent to introduce additional ancillary fares, such as for seat selection, which it also
will not provide to the GDSs. By withholding Add-On Fares from the GDSs, AA obscures the
true all-in cost of its airline tickets, making real comparison shopping more difficult, costly and
time-consuming.
18.

Consumers are and will continue to be harmed by this and other anticompetitive

practices. The Consumer Travel Alliance, Consumer Federation of America, National
Consumers League, and European Consumer’s Federation pointed out some of the reasons in a
letter to the U.S. Department of Transportation on September 20, 2010:
Hidden fees are a violation of a traveler’s most basic right: to know how much
they will have to pay for their trip. When two out of every three air travelers say
they have been surprised by hidden fees at the airport, you know the current
system is broken and needs to be fixed. Airlines should have to share their fees
with every traveler, through every ticketing channel in which they participate, to
every point of sale. With the airline world of fees so complex with so many
variations on each fee, this is the only way consumers can compare prices on the
total cost of travel.
The airlines have every right to make a fair profit and set fares and fees that allow
them to do so. But they have no right to try to hide those prices from their
customers.
19.

In parallel, AA is using its monopoly power over flights at DFW and MIA (and in

other areas) to coerce travel agents and corporate travel purchasers to abandon Sabre and other
GDSs and force them, as a condition of being allowed to issue tickets on AA flights, to use AA’s
proprietary AA Direct Connect CRS exclusively for issuing tickets on AA flights. Unlike the
GDSs, AA’s Direct Connect shows only AA’s own fares and therefore precludes price
comparisons. It cannot be used to book tickets on competing carriers. It cannot be used to book
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App. 9

tickets for a trip that requires flights on more than one carrier (i.e., interline fares).
20.

Travel agencies are typically low margin businesses requiring volume to be

successful. Minimizing the time that it takes to book a flight is therefore critical to their
continued viability. If AA’s information is available only through AA Direct Connect, a travel
agent booking a flight to, from, or through the airports or on routes where AA is dominant will
therefore default to AA Direct Connect, to the exclusion of a GDS, because it will be faster for
the agent to look at a single source to complete a transaction rather than attempting to compare
prices and fare information between different sources. By doing so, the agent will not see
competing flights and fares.
21.

Corporate travel purchasers, such as the travel departments of large companies,

also depend heavily on the ability to effectively comparison shop via a GDS. Corporate travel
purchasers typically employ the services of a travel agency that is equipped with a GDS but in
some cases are themselves subscribers to a GDS. Corporate travel purchasers likewise wish to
minimize the time and cost associated with searching for and booking a flight in order to control
their costs of travel procurement, whether relying on the services of a travel agency or booking
directly in the GDS. But they also need and use comparison shopping to ensure their companies
are obtaining the best possible overall value proposition for their travel needs. GDSs allow
subscribers to comparison shop across multiple airlines and then to track and compare overall
value and to adjust travel policies and purchasing decisions in order to minimize the overall costs
of travel. AA’s Direct Connect would hobble corporate travel purchasers’ ability to comparison
shop and make purchasing decisions in a manner that is cost-effective —particularly in markets
and on routes where AA is dominant.
22.

Because AA will have effectively blocked access by other airlines to a large

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App. 10

segment of travelers in and out of the hubs where AA is dominant, competitors will be
discouraged from attempting to enter or compete in those markets, further entrenching AA’s
monopoly power over those routes.
23.

AA has invited other airlines to take similar steps to compel travel agents and

corporate travel purchasers away from the use of GDSs to shop among competing flights. AA
understands that if the other major airlines, which themselves have routes which they dominate
or monopolize, also withdraw from the GDSs and require travel agents and corporate travel
purchasers to use proprietary, carrier-specific booking channels, its efforts to prevent consumers
from price shopping efficiently will be bolstered. Toward that end, AA has launched a public
and private campaign to encourage other airlines to similarly withhold fare information or
withdraw from the GDSs.
I.

Global Distribution Systems (GDSs), Computerized Reservation Systems (CRSs)
And On-Line Travel Agents (OTAs)
24.

To find fares and other information for flights on AA and other airlines, travel

agents and corporate travel purchasers for decades have used CRSs. The CRSs that operate
globally and independently of any airline control are known as global distribution systems or
“GDSs.” The Sabre GDS brings together in one place fares and travel information from
competing travel suppliers, such as competing airlines, hotels and rental car companies. GDSs
thereby facilitate price competition among carriers and the entry of new and expansion of smaller
carriers serving a route by bringing their offerings to the attention of travelers. This is a
competitive threat to AA.
25.

GDSs facilitate travel agents’ ability to provide timely and efficient services to

their customers by offering the full gamut of supporting technologies and services that fulfill,
monitor, and track reservations from beginning to end. For example, GDSs issue the actual
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App. 11

electronic tickets used by airline travelers. GDSs store passenger reservations for nearly a year,
receive and advise travel agents of any airline schedule changes, process cancellations and
perform refunds and ticket exchanges. GDSs also communicate daily accounting data for
millions of tickets to third-party payment processors so the airlines can get paid. They also
communicate to “back-office” IT systems used by travel agencies for accounting and customer
service, such as passing on automated data to customer expense reporting systems. GDSs also
enable travel agents to save and make use of information about specific customers, such as
personal travel preferences and billing information. Furthermore, GDSs provide valuable
services to the airlines. They provide an efficient and cost-effective channel for selling tickets.
Sabre in particular provides airlines like AA (as well as other travel providers) with broad, realtime, global distribution at thousands of value-added ticket agents and corporate travel
departments. The airlines also benefit from GDSs’ assembly of complementary travel products,
such as flights, hotels, and rental cars, into common delivery channels. Furthermore, because the
GDSs provide customer service for tickets booked through them and increase travel agents’ and
corporate travel purchasers’ ability to provide customer service, they take off the shoulders of the
airlines a substantial portion of customer service costs that airlines would otherwise bear.
26.

Sabre provides services to its customers using one of the most advanced computer

systems in the world, providing tremendous amounts of real-time data on flights, schedules,
fares, and other travel options, and processing tens of thousands of queries every second. Sabre
invests substantial amounts in upgrading and updating its hardware and software to provide the
best service possible to its customers.
27.

Unlike the airlines, GDSs have an incentive to provide the best possible fare

options to their customers—including lowest available fare, best available itinerary, and interline

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flight options. GDSs generally are not compensated based on the price of the tickets booked
through them, but rather on the number of segments sold. Moreover, one of the main benefits a
GDS provides travel agents is efficient, real-time access to low fares. GDSs are therefore highly
motivated to develop features and functions that enable travel agencies and consumers to quickly
and efficiently pinpoint the lowest fare in the market.
28.

Online Travel Agencies (“OTAs”) have become increasingly significant over the

past two decades. OTAs allow individual consumers to shop online directly for airline tickets
and other travel needs. Each OTA utilizes Sabre, Travelport or a competing GDS to provide the
user with fare, schedule, and other information as well as to complete bookings. Sabre Inc. owns
Travelocity, an OTA, which utilizes the Sabre GDS. Other major OTAs include Expedia,
Priceline and Orbitz, which is owned by Travelport.
29.

By providing an on-line platform through which the traveling public can

efficiently shop for fares directly and by offering pro-consumer features such as multi-airline
itineraries, flexible date and alternate airport searches, GDS-powered OTAs have dramatically
increased competition for the supply of travel services resulting in benefits to consumers
including lower air travel prices.
30.

The airline industry itself has acknowledged the consumer benefits of fare

transparency and the ready ability to comparison shop provided by GDSs and OTAs. In his
testimony defending the Delta-Northwest merger before the Senate Judiciary Subcommittee on
Antitrust, Competition Policy & Consumer Rights, then-Northwest CEO Douglas Steenland said
on April 24, 2008:
Over the past several years, online sites such as Orbitz, Expedia, and Travelocity
have been created to enable customers to compare airline offerings directly. . . .
These tools have provided enormous benefits to consumers and have increased
the price-competitiveness of the airline industry. In fact, there are few businesses
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App. 13

in which there is as much pricing transparency.
31.

In short, GDSs have been powerful forces for competition among airlines,

promoting vigorous fare competition and competitive entry.
II.

AA’s Relationship With Sabre And Government Regulation
32.

All of the world’s GDSs were initially owned and operated by airlines. AA

created, and for decades owned and controlled, the Sabre GDS.
33.

Before Sabre became its own company, AA abused its ownership and control of

the Sabre GDS to disadvantage competitors and create market power for itself by, among other
things, biasing searches and displays in favor of AA’s flights. Beginning in the 1980s, the
United States Department of Transportation (and its predecessor the Civil Aeronautics Board)
sought to stop that through regulations that prohibited GDSs that were owned by airlines from
biasing against competing airlines, otherwise distorting competition among airlines, or
misleading consumers. AA’s anticompetitive behavior when it owned and controlled the Sabre
GDS was thus directly responsible for one of the triggering events that led to regulation of
GDSs.
34.

AA initially sold off 18% of Sabre in 1996 for $550 million and then in 2000 spun

off its remaining 82% to shareholders of AMR, the parent company of AA, for total
consideration for AMR and its shareholders of well over one billion dollars.
35.

AA is now seeking to recreate a world where the airlines serve as gatekeepers for

computerized reservation information to the detriment of competition.
III.

AA’s Anticompetitive Campaign To Eliminate GDSs And To Further Solidify Its
Power Over Travel Agents
A.

AA Discontinues Its Long-Standing Practice Of Providing Complete Fare
Information To Sabre

36.

AA has ended its long-standing practice of providing GDSs like Sabre access to
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App. 14

full information about its fares, in particular, access to Add-On Fares. Sabre has made clear to
AA that it is fully able to include Add-On Fares in its normal offering to travel agents and
corporate travel purchasers (as it has always included Complete Fare Information) at no cost to
AA, but AA persists in not providing the information.
37.

Withholding Complete Fare Information from the Sabre GDS and making

Complete Fare Information available only through AA Direct Connect would make no economic
sense for AA absent the anticompetitive effects it will have as detailed herein, including the
elimination of fare transparency. On information and belief, the cost to AA of booking tickets
through the Sabre GDS is less than the cost of doing so through AA Direct Connect. In the
absence of the anticompetitive effects detailed herein, withholding Complete Fare Information
from Sabre and other GDSs would merely reduce AA’s ticket sales and increase its distribution
costs.
38.

AA is the only potential source of AA’s Complete Fare Information, which is

necessary to enable travel agents to complete bookings for AA flights that include Add-On
Fares. AA’s Complete Fare information is essential to Sabre’s continued ability to compete in
the CRS market (particularly as to travel agents and corporate travel purchasers that service
routes and markets where AA is the dominant carrier).
B.

AA Invites Other Airlines To Boycott GDSs And Travel Agents That Use
GDSs

39.

AA has sought to enlist other carriers in its anticompetitive scheme.

40.

Through various means, including public statements at industry conferences and

analyst calls, as well as through airline industry organizations, AA and its agents have actively
invited other airlines to engage in a coordinated anticompetitive strategy of undercutting GDS
systems by pulling their Complete Fare Information (and indeed even the ability to sell their
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App. 15

tickets at all) from travel agents that use the GDSs, in particular from some of the largest OTAs.
41.

In February 2011, a former CEO of AMR (AA’s parent company) was quoted in

an industry publication: “I hope all the airlines follow AA’s example, in which case the airlines
will clearly win.”
42.

At the June 6 to 10, 2010 meeting of the International Air Transportation

Association (“IATA”), an airline trade association on whose Board of Governors AA’s CEO sits,
the Director General lamented that there is too much airline capacity, that the industry is too
fragmented, and that barriers to entry into the airline business are too low—clearly implying that
the group should take action to fix these “problems.” Addressing the attendees who, on
information and belief, included representatives of AA and the other major airlines, he included a
presentation entitled the “Wall of Shame” attacking various regulators and other travel industry
stakeholders who in his view contributed to the industry’s competitiveness, including in
particular the GDSs:

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C.

AA Refuses To Deal With Agents Unless They Agree To Use AA Direct
Connect

43.

As a further part of its scheme, AA has begun to require travel agents to use AA

Direct Connect to access information about, and to book tickets including, Add-On Fares rather
than continue its long-standing practice of providing Complete Fare Information through the
GDS of a travel agent’s choice.
44.

AA’s requirement that travel agents use AA Direct Connect is not limited to Add-

On Fares. AA has indicated that, in the future, it will require agents to use AA Direct Connect to
book any travel on AA flights. In a PowerPoint presentation it has given to agencies, AA has
made this point expressly, stating: “Agencies who connect to the direct connect receive several
benefits” including “[c]ompetitive benefits vs. other agencies not on direct connect and therefore
not able to guarantee access and provide optional services.” “Not able to guarantee access” is a
euphemism for not allowing an agent to book AA flights.
45.

In public statements beginning in late 2009, AA declared that AA Direct Connect

will ultimately be the only way for travel agents to book its flights. According to the Wall Street
Journal in January 2011, AA senior executive Cory Garner said in an interview: “American
remains committed to a wholesale shake-up of its distribution strategy by requiring all external
sellers to access its fares and schedules through a direct electronic link rather than through the
global distribution systems, or GDS . . . . ” (emphasis added).
46.

In private meetings with travel agents and corporate travel departments, AA has

made good on its public threats to refuse to deal with agencies that do not take AA Direct
Connect. For example, in November 2010, AA notified Orbitz, an OTA owned by Travelport,
and publicly signaled to other airlines that, as of December 1, 2010, it would withdraw its
content—all AA fares and schedules—from Orbitz unless Orbitz agreed to use AA Direct
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Connect. On December 21, 2010, AA followed through on its threat, withdrawing its fares from
Orbitz and terminating Orbitz’s right to issue any tickets on AA’s flights. As a result, Orbitz can
no longer display AA content or book AA flights through its website. Orbitz has lost over half
its market capitalization as a result.
D.

AA Ties Access To Its Complete Fare Information To Use Of AA Direct
Connect Service
1.

47.

AA’s Complete Fare Information And AA Direct Connect Are
Separate Products

AA Direct Connect and AA’s Complete Fare Information are both products that

are marketed by AA. Indeed, AA frequently calls its Complete Fare Information “our product.”
There is separate technology underlying AA Direct Connect such as, for example, the Farelogix
FLX platform, a product that purports to compete directly with GDSs. When AA forces a travel
agent or corporate travel purchaser to take AA Direct Connect, it also forces them to take the
separate platform, such as the Farelogix FLX platform.
48.

Both AA and other industry participants recognize AA Direct Connect to be a

product separate and apart from AA’s Complete Fare Information. For example:
a. AA promotes AA Direct Connect as a separate product that competes with
products offered by GDSs;
b. Travel agents consider AA Direct Connect to be a product separate from
AA’s Complete Fare Information; and
c. AA Direct Connect and AA’s Complete Fare Information perform
different functions and provide different benefits to travel agents.
49.

There is a separate demand for AA’s Complete Fare Information and AA Direct

Connect. As discussed above, travel agents and corporate travel purchasers need access to AA’s
Complete Fare Information. Most of them would prefer, however, to continue with their practice
of using a GDS such as Sabre rather than AA Direct Connect.

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50.

There is no technological reason why AA must provide its Complete Fare

Information, including Add-On Fares, only through AA Direct Connect. As noted above, Sabre
has made clear to AA that it is fully able to include Add-on Fares in its normal offering to travel
agents (as it has always included Complete Fare Information). Other GDSs are likewise capable.
For example, Amadeus, a competing GDS, recently announced that it had developed
technological standards allowing travel agents to access and book Add-On Fares offered by
Finnair via the Amadeus GDS. Further, in a letter recently published in The Beat (a travel
business newsletter), Jim Young, executive director of Open Axis (a trade group formed by AA
and five other major domestic airlines) acknowledged: “I think we all know that both the global
distribution systems and direct connect channels (either with or without the GDSs included in the
transaction path) are more than capable of technically handling the complexities of airlines
product distribution now and going forward.” Nevertheless, AA persists in not providing the
information.
2.

51.

AA Is Conditioning Access To Its Complete Fare Information By
Travel Agents On Use Of AA Direct Connect

Even though they are two separate products, AA has made clear that AA is

conditioning access to its Complete Fare Information by travel agents and corporate travel
purchasers on the use of AA Direct Connect.
52.

AA has directly threatened travel agents that if they do not switch to AA Direct

Connect, they will no longer have access to AA’s Complete Fare Information. For example, in
February 2011, AA notified one Sabre customer that if it did not convert to AA Direct Connect,
it would not have access to any AA fare information at all (not just Add-On Fares).
53.

AA told another Sabre customer that eventually every travel agent will need to

convert to AA Direct Connect to get Complete Fare Information (including Add-On Fares). AA
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even threatened that if the agent did not convert immediately, there would be no telling how
much business the agent would lose.
54.

Even where it is not explicitly threatening cutting off a travel agent from AA

booking, AA has in effect threatened the same thing by asserting that it will not process credit
card (or debit card) transactions unless the travel agent uses AA Direct Connect. The ability to
purchase tickets using a credit card is essential; few travelers pay by check or other forms of
payment, and requiring a customer to do so would place a travel agent at a severe competitive
disadvantage given consumers’ preference for using credit cards for large purchases. Indeed, in
a recent period, well over 90% of tickets sold through the Sabre GDS were charged to a credit
card. Nor can a travel agent economically act as the merchant of record for credit card
transactions if AA refused to do so because the interchange fee it would incur would typically
dwarf the fees received by the travel agent for its services.
55.

Losing the ability to book tickets via credit card is therefore akin to losing the

ability to book tickets. In threatening to block the use of credit cards, AA in effect conditions the
ability to book an AA ticket on the use of AA Direct Connect.
3.

56.

Travel Agents Would Not Choose To Use AA Direct Connect On The
Merits

But for AA’s tying of Complete Fare Information to AA Direct Connect, few if

any travel agents or corporate travel purchasers would use AA Direct Connect. The vast
majority of travel agents and other potential AA Direct Connect customers prefer GDSs to AA
Direct Connect. AA Direct Connect’s unproven and inefficient technology has simply not been
welcomed by the marketplace on its own merits, while GDSs’ – and in particular the Sabre
GDS’s – technology and broad offering of services continue to be highly valued and preferred by
travel agents around the country.
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57.

Earlier this year, the American Society of Travel Agents (“ASTA”) issued a

statement criticizing AA’s direct connect strategy. ASTA represents a majority of the travel
agents in the United States. ASTA said that AA’s direct connect program “threatens to produce
expensive and complex ‘de-integration’ of efficient information flows that have benefited
consumers of air travel for decades.”
58.

The National Business Travel Association (“NBTA”), which represents over five

thousand corporate members in 30 countries, has also criticized AA’s direct connect scheme.
NBTA’s executive director and COO warned: “Business travel buyers will ultimately foot the
bill for marketplace fragmentation caused by airline initiatives that push the travel distribution
marketplace in the wrong direction—away from transparency and competitiveness toward
confusion and higher costs.”
59.

The NBTA surveyed its membership and issued a press release on January 28,

2011, confirming that its members were solidly opposed to efforts to force agents to accept AA
Direct Connect:
A new survey of 244 business travel buyers released today by the National
Business Travel Association (NBTA) Foundation has revealed that a vast majority
of respondents (89%) expect an increase in travel costs if the airline industry
moves to a “Direct Connect” model that bypasses the existing travel distribution
system. Almost three-quarters (72%) believe a shift to a Direct Connect-type
system would have a negative impact on the business travel industry, and over
half (59%) of travel managers said they would be “very concerned” if other
airlines pursue similar distribution strategies.
“Business travel buyers have spoken and they overwhelmingly indicate that the
“direct connect” approach for airfare distribution is a pricey strategy that will
result in higher costs for companies and negatively impact the business travel
industry as a whole,” said Mike McCormick, executive director and COO, NBTA.
60.

The Business Travel Coalition (“BTC”), which represents corporate officials

responsible for travel procurement, also criticized AA’s attempts to impose its AA Direct

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Connect system on travel agents. According to BTC’s Chairman: “The stakes in this conflict
are clear: either an improved airline industry and distribution marketplace centered around the
consumer, or one that subordinates consumer interests to the self-serving motivations of
individual airlines endeavoring to shift costs and impose their wills on consumers and the other
participants in the travel industry.” He warned that AA’s strategy threatened to undermine
numerous important benefits of the current distribution system: (1) robust comparison shopping
among airlines’ offerings for consumers and corporate travelers using on-line booking tools; (2)
efficiencies inherent in one integrated workflow process for shopping for travel services; and (3)
transparency and pricing discipline that tens of thousands of independent online and offline
travel agents bring to all offerings on a travel suppliers’ own websites and other distribution
channels.
61.

BTC reported that interim results from a survey of corporate travel managers

showed that 98% do not support AA’s direct connect strategy and that 94% indicated that access
to all airfare and ancillary fee information (i.e., Add-On Fares) is either indispensably important
or very important for their corporate managed travel programs.
62.

Nevertheless, travel agents and corporate travel purchasers will be forced to use

the AA Direct Connect product because that will be the only way for them to get access to
Complete Fair Information.
63.

A number of customers have already agreed to AA’s tie. Priceline, one of the

largest OTAs in the country, has accepted AA’s tie of AA Direct Connect to access and book
AA’s Complete Fare Information—despite having a preference for using the GDS systems to
access and book AA fares. Priceline indicated to Sabre that AA Direct Connect is inefficient and
that Priceline would prefer not to use it. But Priceline nevertheless was forced to use AA Direct

18

App. 22

Connect in order to get access to critical AA fare information. Ryan Mikolasik, an AA
spokesman, confirmed that because Priceline is now using AA Direct Connect, it has access to
AA’s full content: “Priceline has access to our full content through direct connect (fares,
schedules, as well as ancillary products, including the Your Choice Boarding and Flexibility
package we launched last year).”
64.

Vegas.com, another large OTA, has likewise accepted AA’s tie. AA itself has

indicated that others have accepted AA’s tie as well. According to the Wall Street Journal, AA
senior executive Cory Garner said: “online and bricks-and-mortar travel agents in the U.S.,
Europe and Asia have already signed up to Direct Connect . . . .”
65.

A travel agent in Fort Worth, Texas, recently agreed to take the AA Direct

Connect product after AA threatened that the travel agent may no longer have access to AA’s
Complete Fare Information through the Sabre GDS. The travel agent did not want to take AA
Direct Connect because it is awkward and would slow the travel agent down considerably, but
nevertheless took it so as to have access to AA Complete Fare Information (and the ability to
book AA tickets at all), which it feared would not be available through the GDS.
66.

Another travel agent Sabre customer in Chicago reported that an AA

representative had visited its office insisting that the travel agent install AA Direct Connect. The
AA representative told the agent that eventually everyone will have to convert to AA Direct
Connect and that if the travel agent did not convert now, there is no telling how long it would
have to wait and how much business it would lose. The agent felt pressured by AA. Such
threats are consistent with AA’s use of its market power to force travel agents to take products
they do not want.
67.

Rearden, which provides back office software travel tools for corporate travel

19

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purchasers, has also recently agreed to take AA Direct Connect despite not wanting to do so.
Although Rearden is not itself a travel agent or corporate travel purchaser, it provides the
interface for many corporate travel purchasers. Its decision to accept Direct Connect rather than
rely on the GDSs for AA fare information will impact Rearden’s many customers, increasing the
likelihood they will also be forced to take Direct Connect. Rearden acquiesced to the use of AA
Direct Connect only after AA threatened not to provide its Complete Fare Information to
Rearden.
4.
68.

AA’s Conduct Affects A Substantial Volume Of Commerce

Unless restrained, AA’s actions will affect a not insubstantial amount of

commerce in the CRS market. Even a tiny fraction of the fees for booking AA flights translates
into multiple millions of dollars annually, not to mention fees for related bookings (such as
hotels and rental cars).

ANTICOMPETITIVE EFFECTS
I.

Relevant Markets
69.

There are several relevant markets in this case.

70.

First, there are city pairs set forth in Exhibit A (the “Relevant City Pairs”). There

are no reasonable substitutes for air travel between two cities in a pair (for example, travel from
Boston to New York is not a substitute for travel from Wichita to Dallas). Moreover, even as
between two airports, direct service is a different market than connecting service, as travelers
will pay significantly more for direct service. For example, a non-stop ticket between LaGuardia
airport in New York City and DFW on average costs roughly 2.4 times more than a ticket for
connecting service.
71.

There are significant barriers to entry for each Relevant City Pair, including the

need for equipment, an FAA license, gates at the relevant airports, consumer reputation, and a
20

App. 24

viable frequent flyer program.
72.

An airline with a monopoly in one of these city pairs therefore could charge the

monopoly price for travel between the two cities in the pair.
73.

Second, there is the related market for Complete Fare Information for each

Relevant City Pair. There is no substitute for such information when choosing a flight between a
Relevant City Pair.
74.

Third, there is a relevant market for computerized reservation systems in the

United States, which include GDSs and AA Direct Connect (the “CRS Market”).
75.

For travel agents who book numerous transactions for multiple clients every day,

there are no reasonable substitutes for CRSs. CRSs allow travel agents to quickly and visually
access fare and other information and to book travel over the internet or other computer
connection.
76.

Fourth, there is a relevant market for electronic booking of travel between the

Relevant City Pairs (the “Relevant City Pair Booking Service Market”). Presently this market
includes the GDSs (and the OTAs that use GDSs), AA Direct Connect, and AA.com. For travel
agents and consumers booking flights on AA-dominated routes, there is no substitute for one of
those services.
II.

AA’s Market Power
A.
77.

AA Dominates Many Routes
To be viable in most geographic areas in the United States, a travel agent must

have access to AA flights. In 2010 AA had a 100% share of non-stop domestic flights between
348 domestic city pairs and 100% share of non-stop international flights between 74 domesticinternational city pairs. In 2010 AA had 70% to 99% share of non-stop seat capacity on
domestic flights between 51 additional domestic city pairs and 70% to 99% share of non-stop
21

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seat capacity on international flights between 30 additional domestic-international city pairs.
These shares are conservative—they assume that airports servicing the same city (such as Love
Field and DFW) are reasonable substitutes even though for a substantial number of travelers
they are not. Access to AA booking is therefore critical for travel agents and corporate travel
purchasers.
78.

In the Dallas/Fort Worth, Miami, and Chicago areas, for example, such access is

critical because so many flights out of DFW, MIA and Chicago’s O’Hare airport (“ORD”) and
between the United States and the Caribbean are AA flights. As Exhibit A demonstrates, for
many of the destinations it serves from DFW and Miami, AA is the only non-stop option, and it
seldom competes with more than one other carrier on any non-stop route. Given the frequency
of flights it offers out of Dallas/Fort Worth and Miami, and the relative lack of non-stop options
at the same frequency from other airlines, AA’s dominance is even more pronounced for
business travelers, who are often the main customers of travel agencies and are the main
customers for corporate travel purchasers.
79.

In other areas, access is critical because of the volume of travel to Dallas/Fort

Worth, Miami, and Chicago, both as destinations, and as transfer points to international flights to
Latin America, Asia, and Europe. In addition, as to certain international routes, particularly to
the Caribbean, AA dominates flights from other embarkation points as well.
80.

In particular, AA accounted for roughly 86% of all seats originating from DFW

airport in 2010. Even if the other smaller airport serving the Dallas/Fort Worth Area (Love
Field) were included, AA remains the dominant carrier for flights originating from Dallas/Fort
Worth, accounting for roughly 74% of all seats originating from DFW and Love Field in 2010
and roughly 55% of all passengers originating from the Dallas/Fort Worth area in 2010.

22

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81.

AA accounted for roughly 70% of all seats originating from MIA (and hence the

Miami area) in 2010 and roughly 51% of all passengers originating from MIA, which is the only
commercial airport in the Miami area.
82.

AA also has market power in city pairs originating in Chicago. AA has a

substantial share of flights departing from the Chicago area. AA accounted for roughly 35% of
all seats originating from ORD in 2010, 28% of all seats originating from ORD and Midway
Airport combined, and 25% of all passengers originating from the two airports in 2010.
Although Midway airport also services Chicago, many routes from Chicago are serviced only
from ORD and, in addition, for a substantial number of airline travelers in the Chicago area,
Midway is not a viable option due to longer travel times to Midway as compared to ORD.
Accordingly, AA’s pricing of flights between ORD and many destinations is not constrained by
the prices of flights to or from Midway Airport, or at most is constrained to a limited degree.
83.

AA also has monopoly power in various Caribbean markets. AA provides the

only flight options for travel between many U.S. cities and destinations within the Caribbean as
well as between cities in the Caribbean itself. Therefore, a travel agent serving customers
wishing to travel to, from or within the Caribbean must have access to AA’s Complete Fare
Information and the ability to book on AA. Without the ability to sell AA tickets including AddOn Fares to the Caribbean, a travel agent catering to travelers to, from or within the Caribbean
would not be competitive.
84.

As set forth in Exhibit A, in 2010 AA accounted for 100% of non-stop flights on

44 different routes between cities in the United States and the Caribbean, and 70% to 99% of
non-stop seat capacity on another 16 such routes. In 2010 AA accounted for 100% of non-stop
flights on 25 routes between cities within the Caribbean, and 70% to 99% of non-stop seat

23

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capacity on another eight such routes. In 2010 AA also accounted for 100% of non-stop flights
between the important business centers of Dallas/Fort Worth and Tokyo as well as all flights
between San Juan, Puerto Rico, and Caracas, Venezuela.
85.

AA’s market power is strengthened still further by its frequent flyer program.

Travelers in areas dominated by a carrier – such as AA in Dallas/Fort Worth or Miami – tend to
accumulate “points” in that carrier’s frequent flyer program. Frequent flyer programs encourage
customer loyalty (i.e., the use of a particular carrier even when a competing carrier has a lower
fare or otherwise has a more competitive alternative) by offering free tickets and highly coveted
benefits—such as complimentary seat upgrades, priority check-in service, and priority boarding,
among others—for meeting certain flight mile benchmarks. AA’s AAdvantage frequent flyer
program is the largest in the world and, even more than other such programs, creates a barrier to
competitive entry which enhances AA’s market power.
B.

AA Has Monopoly Power Over Complete Fare Information For The Routes
It Dominates

86.

AA has monopoly power over Complete Fare Information for flights between the

Relevant City Pairs. Hence, AA has appreciable economic power over travel agents and
corporate travel purchasers who serve customers flying between the Relevant City Pairs because
those travel agents need access to AA’s Complete Fare Information in order to remain
competitive.
C.

As A Result Of AA’s Conduct, Competition And Consumers Will Be Harmed

87.

By eliminating price transparency and creating disabling disincentives to

comparison shopping, AA’s anticompetitive scheme will undermine efficient comparison
shopping, hurt competitors in routes that AA dominates, make competitive entry more expensive
and less likely, and will thereby maintain AA’s monopoly on those routes. It also presents the
24

App. 28

dangerous probability that AA will gain a monopoly over the Relevant City Pair Booking
Service Market, over which it already has a substantial share through its website, AA.com, which
is separate from AA Direct Connect.
88.

Travel agents and corporate travel purchasers cannot economically shop in

multiple airline systems for the full, all-in costs of air travel including Add-On Fares. Travel
agents and corporate travel purchasers accordingly will not expend the costs to search for
alternative flights on other carriers, which will free AA to raise prices and will also make it more
difficult for potential entrants on routes that AA dominates or nearly dominates to cut into AA’s
market power by initiating or expanding service.
89.

By not providing Complete Fare Information, AA’s flights will also appear less

expensive, introducing systematic and persistent “display bias” that will further diminish the
ability of more efficient competitors or new entrants to compete in the AA monopoly markets.
AA’s flights will appear artificially “higher” on the travel agent’s (or consumer’s) screen when
search results are sorted by fare than those flights would be placed if their listed fare included all
of the related Add-On Fares. This in itself can profoundly affect competition.
90.

Of course, the AA Direct Connect system represents the ultimate biasing in favor

of AA because it excludes all information about competing flights altogether. Travel agents and
corporate travel purchasers servicing AA dominant routes will naturally look first at flight
options on AA Direct Connect and, in many cases, will not compare those fares to competing
offerings from other airlines because doing so would require the travel agent or corporate travel
purchaser to access and run searches on another system, such as the Sabre GDS, and then
perform a manual fare comparison. Because travel agents and even corporate travel purchasers
tend to book one of the first flights displayed to them and generally work under time pressure,

25

App. 29

they are unlikely to search through several display screens. AA’s goal is that travel agents and
corporate travel purchasers will look first and only at AA fares in order to avoid such tedious,
inefficient and uneconomic comparisons.
91.

AA has admitted that it intends to use its direct connect strategy to increase

revenues, and not to decrease its costs. Gerard Arpey, AA’s Chairman and CEO recently made
clear that AA’s strategy is not aimed at changing AA’s costs, specifically stating, “[t]hinking of
distribution from a cost stand point is the wrong way to think about it.” Instead, Isabella Goren,
AA’s Chief Financial Officer and Senior Vice President, stated that AA’s end-game in its
campaign against the GDSs is to enable AA to “derive greater revenues.”
92.

AA’s conduct ultimately will result in higher airline ticket prices as pricing

transparency declines, and with it the incentives for AA to match low fares. The inability to
market flights through GDSs will reduce the possibility of competitive entry, which will increase
price and reduce options for travelers. Travelers will face increased prices, less negotiating
power, loss of volume discounts, new fees and processing costs, lower rebates, lost savings,
difficulties in re-accommodation and other process inefficiencies.
D.

As A Result Of AA’s Conduct, Sabre Has Suffered And Will Suffer
Significant And Imminent Harm

93.

By tying its Complete Fare Information to its separate AA Direct Connect

product, AA will, unless restrained, substantially foreclose its GDS competitors, including Sabre,
from providing their services to travel agents and corporate travel purchasers. AA’s tying will
sharply reduce demand for Sabre’s GDS product, even by travel agents and corporate travel
purchasers who would otherwise prefer to use Sabre’s GDS. Further, AA cannot achieve its goal
of defeating fare transparency and comparison shopping without pressuring travel agencies and
corporate travel purchasers away from their use of the Sabre GDS. AA’s anticompetitive
26

App. 30

scheme is therefore inextricably intertwined with and dependent upon the injury caused to Sabre.
As discussed above, AA’s strategy has already foreclosed Sabre from providing its services to a
number of customers.
94.

In addition, at least one Florida travel agent who had committed to converting to

the Sabre GDS (from the Amadeus GDS) has subsequently refused to do so based on AA’s
statements that it would not be providing its content through Sabre and that it otherwise wanted
to get out of the GDSs. Because the travel agent books roughly 90% of its business with AA, it
backed out of its agreement to convert to Sabre after being confronted by AA.
95.

As a result of AA’s conduct, Sabre has suffered and will suffer imminent and

significant harm.

CLAIMS FOR RELIEF
COUNT I – MONOPOLIZATION OF THE RELEVANT CITY PAIRS
96.

Sabre alleges and incorporates herein by reference the allegations stated in

paragraphs 1 through 96 above.
97.

Through its actions, AA is willfully maintaining (or threatening to willfully

maintain) its monopoly over the provisioning of air transportation between the Relevant City
Pairs in violation of Section 2 of the Sherman Act. By eliminating Sabre and other GDSs by
refusing to provide Complete Fare Information and by requiring travel agents and corporate
travel purchasers to use AA Direct Connect rather than a GDS, AA reduces competition in the
Relevant City Pairs and thwarts potential competitive entry in providing air transportation
between the Relevant City Pairs.
98.

There is no lawful justification for AA’s conduct.

99.

Sabre has suffered injury to its business as a direct result of AA’s conduct.

27

App. 31

100.

AA’s conduct presents an imminent threat of causing significant injury to Sabre’s

business, competition, and consumers.
COUNT II – ATTEMPTED MONOPOLIZATION OF THE RELEVANT CITY-PAIRS
101.

Sabre alleges and incorporates herein by reference the allegations stated in

paragraphs 1 through 96 above.
102.

Through its actions, AA is attempting to monopolize the provisioning of air

transportation service between the Relevant City Pairs in violation of Section 2 of the Sherman
Act. As shown in Exhibit A, AA has a substantial share of those markets already. By
eliminating Sabre and other GDSs by refusing to provide Complete Fare Information and by
requiring travel agents and corporate travel purchasers to use AA Direct Connect rather than a
GDS, AA reduces competition in the Relevant City Pairs and thwarts potential competitive entry
in providing air transportation between the Relevant City Pairs. AA also has invited other
airlines to take similar steps, which would balkanize air travel in the United States further, giving
AA monopoly power over the remaining Relevant City Pairs. There is thus a dangerous
probability that AA will succeed in obtaining monopolies over the provisioning of air
transportation services between the Relevant City Pairs, to the extent it does not have such
monopolies already.
103.

There is no lawful justification for AA’s conduct.

104.

Sabre has suffered injury to its business as a direct result of AA’s conduct.

105.

AA’s conduct presents an imminent threat of causing significant injury to Sabre’s

business, competition, and consumers.
COUNT III – ATTEMPTED MONOPOLIZATION OF THE RELEVANT CITY PAIR BOOKING SERVICE
MARKET
106.

Sabre alleges and incorporates herein by reference the allegations stated in
28

App. 32

paragraphs 1 through 96 above.
107.

Through its actions, AA is attempting to monopolize the Relevant City Pair

Booking Service Market by making it impossible for the other current participants in that market,
including Sabre, to continue to participate, in violation of Section 2 of the Sherman Act. By
eliminating Sabre, the other GDSs including Travelport and OTAs, by refusing to provide
Complete Fare Information and by requiring travel agents and corporate travel purchasers to use
AA Direct Connect rather than a GDS, AA will eliminate the ability of any competitors in that
market to compete. There is thus a dangerous probability that AA will succeed in obtaining a
monopoly over the Relevant City Pair Booking Service Market.
108.

There is no lawful justification for AA’s conduct.

109.

Sabre has suffered injury to its business as a direct result of AA’s conduct.

110.

AA’s conduct presents an imminent threat of causing significant injury to Sabre’s

business, competition, and consumers.
COUNT IV – UNLAWFUL TYING OF ACCESS TO COMPLETE FARE INFORMATION TO AA DIRECT
CONNECT IN VIOLATION OF 15 U.S.C. § 1
111.

Sabre alleges and incorporate herein by reference the allegations stated in

paragraphs 1 through 96 above.
112.

AA has appreciable economic power in the markets for Complete Fare

Information for flights originating from Dallas, Miami, and Chicago, to, from or within the
Caribbean, and between the Relevant City Pairs. Accordingly, AA has power over travel agents
and corporate travel purchasers who need to service customers who demand access to AA fare
information and flights, and, in particular, those traveling to and from Dallas, Miami, and
Chicago, to, from or within the Caribbean, as well as between the Relevant City Pairs set forth in
Exhibit A to this Complaint.
29

App. 33

113.

The AA Direct Connect CRS is a separate and distinct product from AA’s

Complete Fare Information. The AA Direct Connect competes with the Sabre GDS, and other
GDSs in the CRS market.
114.

AA has conditioned and has announced plans to continue to condition access to

its Complete Fare Information on the taking of its AA Direct Connect CRS.
115.

A substantial number of travel agents have already agreed to use AA Direct

Connect because of AA’s tie, and AA’s actions have affected and threaten to affect a not
insubstantial amount of commerce in the CRS market.
116.

The agreements that AA has entered with travel agents are per se unreasonable

restraints of trade. In addition, AA’s actions have had and will have an anticompetitive effect.
117.

There is no lawful justification for AA’s conduct.

118.

Sabre has suffered injury to its business as a direct result of AA’s conduct.

119.

AA’s conduct presents an imminent threat of causing significant injury to Sabre’s

business, competition, and consumers.

PRAYER FOR RELIEF
Accordingly, plaintiffs pray for entry of judgment in their favor as follows:
a.

A decree that AA has violated, and threatens to continue violating, 15 U.S.C. § 2;

b.

A decree that AA has violated, and threatens to continue violating, 15 U.S.C. § 1;

c.

A permanent injunction requiring AA to provide its Complete Fare Information to
Sabre and prohibiting AA and its agents, servants, employees, affiliates, divisions,
and subsidiaries, and those in association with them, from tying AA’s Complete
Fare Information to its separate AA Direct Connect product;

d.

An award of three times Sabre’s actual damages;

30

App. 34

e.

An award of all costs in this action, including attorneys’ fees and interest; and

f.

Such other relief as this Court deems proper.

JURY DEMAND
Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, plaintiffs demand a trial
by jury on all issues so triable.
Dated: ________________

Ralph H. Duggins ([e-mail])
State Bar No. 06183700
Scott A. Fredricks ([e-mail])
State Bar No. 24012657
Philip A. Vickers ([e-mail])
State Bar No. 24051699
CANTEY HANGER LLP
600 West 6th Street, #300
Fort Worth, TX 76102
Telephone: [phone]
Facsimile: [phone]
Don Scott ([e-mail])
Karma Giulianelli ([e-mail])
Sean Grimsley ([e-mail])
Sundeep (Rob) K. Addy ([e-mail]
BARTLIT BECK HERMAN PALENCHAR
& SCOTT LLP
1899 Wynkoop Street, Suite 800
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Chris Lind ([e-mail])
Andrew Polovin ([e-mail])
Katherine M. Swift ([e-mail])
BARTLIT BECK HERMAN PALENCHAR
& SCOTT LLP
54 West Hubbard Street
Chicago, IL 60610
Telephone: [phone]
Facsimile: [phone]
George S. Cary ([e-mail])
Steven J. Kaiser ([e-mail])
CLEARY GOTTLIEB STEEN &
31

App. 35

HAMILTON LLP
2000 Pennsylvania Ave., N.W.
Washington, DC 20006
Telephone: [phone]
Facsimile: [phone]
Counsel for Intervenors Sabre Inc. and
Sabre Travel International Ltd.

32

App. 36

CERTIFICATE OF SERVICE
This is to certify that on this __ day of ________, a true and correct copy of the foregoing
document was filed electronically via the CM/ECF system, which gave notice to all counsel of
record.
_
Scott A. Fredricks

33

App. 37

EXHIBIT A – Relevant City Pairs1
Domestic U.S. City Pairs (Origin-Destination) in which AA had
100% of non-stop flights in 2010
1. Abilene (ABI)-Dallas/Ft Worth (DFW,DAL)
2. Albuquerque (ABQ)-Dallas/Ft Worth (DFW,DAL)
3. Waco (ACT)-Dallas/Ft Worth (DFW,DAL)
4. Alexandria, LA (AEX)-Dallas/Ft Worth (DFW,DAL)
5. Augusta (AGS)-Dallas/Ft Worth (DFW,DAL)
6. Amarillo (AMA)-Dallas/Ft Worth (DFW,DAL)
7. Anchorage (ANC)-Dallas/Ft Worth (DFW,DAL)
8. Austin (AUS)-St Louis (STL)
9. Asheville (AVL)-Dallas/Ft Worth (DFW,DAL)
10. Kalamazoo (AZO)-Chicago (ORD,MDW)
11. Hartford (BDL)-Dallas/Ft Worth (DFW,DAL)
12. Hartford (BDL)-Miami (MIA)
13. Hartford (BDL)-San Juan, PR (SJU)
14. Birmingham (BHM)-Dallas/Ft Worth (DFW,DAL)
15. Birmingham (BHM)-Miami (MIA)
16. Bloomington (BMI)-Chicago (ORD,MDW)
17. Bloomington (BMI)-Dallas/Ft Worth (DFW,DAL)
18. Nashville (BNA)-Dallas/Ft Worth (DFW,DAL)
19. Nashville (BNA)-Miami (MIA)
20. Boston (BOS)-Dallas/Ft Worth (DFW,DAL)
21. Boston (BOS)-Miami (MIA)
22. Brownsville (BRO)-Dallas/Ft Worth (DFW,DAL)
23. Baton Rouge (BTR)-Dallas/Ft Worth (DFW,DAL)
24. Columbia, SC (CAE)-Dallas/Ft Worth (DFW,DAL)
25. Chattanooga (CHA)-Chicago (ORD,MDW)
26. Chattanooga (CHA)-Dallas/Ft Worth (DFW,DAL)
27. Chicago (ORD,MDW)-Kalamazoo (AZO)
28. Chicago (ORD,MDW)-Bloomington (BMI)
29. Chicago (ORD,MDW)-Chattanooga (CHA)
30. Chicago (ORD,MDW)-Champaign (CMI)
31. Chicago (ORD,MDW)-Dubuque (DBQ)
32. Chicago (ORD,MDW)-Vail/Eagle (EGE)
33. Chicago (ORD,MDW)-Evansville, IN (EVV)
34. Chicago (ORD,MDW)-Flint (FNT)
35. Chicago (ORD,MDW)-La Crosse (LSE)
36. Chicago (ORD,MDW)-Manhattan, KS (MHK)
37. Chicago (ORD,MDW)-Marquette, MI (SAW)
38. Chicago (ORD,MDW)-West Palm Beach (PBI)
39. Chicago (ORD,MDW)-Reno (RNO)
1

City-pairs include services between all airports that may service a particular city or set of cities. The airport codes
for each city or set of cities are indicated in parentheses.

34

App. 38

40. Chicago (ORD,MDW)-Rochester (RST)
41. Chicago (ORD,MDW)-Toledo (TOL)
42. Chicago (ORD,MDW)-Bristol (TRI)
43. Chicago (ORD,MDW)-Tucson (TUS)
44. Charleston, SC (CHS)-Dallas/Ft Worth (DFW,DAL)
45. Charleston, SC (CHS)-Miami (MIA)
46. Cedar Rapids (CID)-Dallas/Ft Worth (DFW,DAL)
47. College Station (CLL)-Dallas/Ft Worth (DFW,DAL)
48. Columbus, OH (CMH)-Dallas/Ft Worth (DFW,DAL)
49. Columbus, OH (CMH)-Miami (MIA)
50. Champaign (CMI)-Chicago (ORD,MDW)
51. Champaign (CMI)-Dallas/Ft Worth (DFW,DAL)
52. Colorado Springs (COS)-Dallas/Ft Worth (DFW,DAL)
53. Corpus Christi (CRP)-Dallas/Ft Worth (DFW,DAL)
54. Charleston (CRW)-NYC (LGA,EWR,JFK)
55. Columbus, GA (CSG)-Dallas/Ft Worth (DFW,DAL)
56. Cheyenne (CYS)-Dallas/Ft Worth (DFW,DAL)
57. Dayton (DAY)-Dallas/Ft Worth (DFW,DAL)
58. Dubuque (DBQ)-Chicago (ORD,MDW)
59. Des Moines (DSM)-Dallas/Ft Worth (DFW,DAL)
60. Des Moines (DSM)-St Louis (STL)
61. Dallas/Ft Worth (DFW,DAL)-Abilene (ABI)
62. Dallas/Ft Worth (DFW,DAL)-Albuquerque (ABQ)
63. Dallas/Ft Worth (DFW,DAL)-Waco (ACT)
64. Dallas/Ft Worth (DFW,DAL)-Alexandria, LA (AEX)
65. Dallas/Ft Worth (DFW,DAL)-Augusta (AGS)
66. Dallas/Ft Worth (DFW,DAL)-Amarillo (AMA)
67. Dallas/Ft Worth (DFW,DAL)-Anchorage (ANC)
68. Dallas/Ft Worth (DFW,DAL)-Asheville (AVL)
69. Dallas/Ft Worth (DFW,DAL)-Hartford (BDL)
70. Dallas/Ft Worth (DFW,DAL)-Birmingham (BHM)
71. Dallas/Ft Worth (DFW,DAL)-Bloomington (BMI)
72. Dallas/Ft Worth (DFW,DAL)-Nashville (BNA)
73. Dallas/Ft Worth (DFW,DAL)-Boston (BOS)
74. Dallas/Ft Worth (DFW,DAL)-Brownsville (BRO)
75. Dallas/Ft Worth (DFW,DAL)-Baton Rouge (BTR)
76. Dallas/Ft Worth (DFW,DAL)-Columbia, SC (CAE)
77. Dallas/Ft Worth (DFW,DAL)-Chattanooga (CHA)
78. Dallas/Ft Worth (DFW,DAL)-Charleston, SC (CHS)
79. Dallas/Ft Worth (DFW,DAL)-Cedar Rapids (CID)
80. Dallas/Ft Worth (DFW,DAL)-College Station (CLL)
81. Dallas/Ft Worth (DFW,DAL)-Columbus, OH (CMH)
82. Dallas/Ft Worth (DFW,DAL)-Champaign (CMI)
83. Dallas/Ft Worth (DFW,DAL)-Colorado Springs (COS)
84. Dallas/Ft Worth (DFW,DAL)-Corpus Christi (CRP)
85. Dallas/Ft Worth (DFW,DAL)-Columbus, GA (CSG)
35

App. 39

86. Dallas/Ft Worth (DFW,DAL)-Cheyenne (CYS)
87. Dallas/Ft Worth (DFW,DAL)-Dayton (DAY)
88. Dallas/Ft Worth (DFW,DAL)-Des Moines (DSM)
89. Dallas/Ft Worth (DFW,DAL)-Vail/Eagle (EGE)
90. Dallas/Ft Worth (DFW,DAL)-El Paso (ELP)
91. Dallas/Ft Worth (DFW,DAL)-Evansville, IN (EVV)
92. Dallas/Ft Worth (DFW,DAL)-Fresno (FAT)
93. Dallas/Ft Worth (DFW,DAL)-Fayetteville, NC (FAY)
94. Dallas/Ft Worth (DFW,DAL)-Ft Lauderdale (FLL)
95. Dallas/Ft Worth (DFW,DAL)-Sioux Falls (FSD)
96. Dallas/Ft Worth (DFW,DAL)-Ft Smith, AR (FSM)
97. Dallas/Ft Worth (DFW,DAL)-Ft Wayne (FWA)
98. Dallas/Ft Worth (DFW,DAL)-Longview, TX (GGG)
99. Dallas/Ft Worth (DFW,DAL)-Grand Junction (GJT)
100.
Dallas/Ft Worth (DFW,DAL)-Gulfport (GPT)
101.
Dallas/Ft Worth (DFW,DAL)-Killeen (GRK)
102.
Dallas/Ft Worth (DFW,DAL)-Grand Rapids (GRR)
103.
Dallas/Ft Worth (DFW,DAL)-Greensboro, NC (GSO)
104.
Dallas/Ft Worth (DFW,DAL)-Greenville, SC (GSP)
105.
Dallas/Ft Worth (DFW,DAL)-Gunnison (GUC)
106.
Dallas/Ft Worth (DFW,DAL)-Hayden, CO (HDN)
107.
Dallas/Ft Worth (DFW,DAL)-Honolulu (HNL)
108.
Dallas/Ft Worth (DFW,DAL)-Huntsville, AL (HSV)
109.
Dallas/Ft Worth (DFW,DAL)-Wichita (ICT)
110.
Dallas/Ft Worth (DFW,DAL)-Indianapolis (IND)
111.
Dallas/Ft Worth (DFW,DAL)-Jackson, WY (JAC)
112.
Dallas/Ft Worth (DFW,DAL)-Jackson, MS (JAN)
113.
Dallas/Ft Worth (DFW,DAL)-Jacksonville (JAX)
114.
Dallas/Ft Worth (DFW,DAL)-Lawton, OK (LAW)
115.
Dallas/Ft Worth (DFW,DAL)-Lubbock (LBB)
116.
Dallas/Ft Worth (DFW,DAL)-Lake Charles (LCH)
117.
Dallas/Ft Worth (DFW,DAL)-Lexington (LEX)
118.
Dallas/Ft Worth (DFW,DAL)-Lafayette, LA (LFT)
119.
Dallas/Ft Worth (DFW,DAL)-Little Rock (LIT)
120.
Dallas/Ft Worth (DFW,DAL)-Laredo (LRD)
121.
Dallas/Ft Worth (DFW,DAL)-Midland (MAF)
122.
Dallas/Ft Worth (DFW,DAL)-McAllen (MFE)
123.
Dallas/Ft Worth (DFW,DAL)-Montgomery (MGM)
124.
Dallas/Ft Worth (DFW,DAL)-Manhattan, KS (MHK)
125.
Dallas/Ft Worth (DFW,DAL)-Miami (MIA)
126.
Dallas/Ft Worth (DFW,DAL)-Moline (MLI)
127.
Dallas/Ft Worth (DFW,DAL)-Monroe, LA (MLU)
128.
Dallas/Ft Worth (DFW,DAL)-Mobile (MOB)
129.
Dallas/Ft Worth (DFW,DAL)-Madison (MSN)
130.
Dallas/Ft Worth (DFW,DAL)-New Orleans (MSY)
131.
Dallas/Ft Worth (DFW,DAL)-Montrose (MTJ)
36

App. 40

132.
133.
134.
135.
136.
137.
138.
139.
140.
141.
142.
143.
144.
145.
146.
147.
148.
149.
150.
151.
152.
153.
154.
155.
156.
157.
158.
159.
160.
161.
162.
163.
164.
165.
166.
167.
168.
169.
170.
171.
172.
173.
174.
175.
176.
177.

Dallas/Ft Worth (DFW,DAL)-Myrtle Beach (MYR)
Dallas/Ft Worth (DFW,DAL)-Kahului, HI (OGG)
Dallas/Ft Worth (DFW,DAL)-Oklahoma City (OKC)
Dallas/Ft Worth (DFW,DAL)-Omaha (OMA)
Dallas/Ft Worth (DFW,DAL)-Norfolk (ORF)
Dallas/Ft Worth (DFW,DAL)-West Palm Beach (PBI)
Dallas/Ft Worth (DFW,DAL)-Portland, OR (PDX)
Dallas/Ft Worth (DFW,DAL)-Peoria (PIA)
Dallas/Ft Worth (DFW,DAL)-Pittsburgh (PIT)
Dallas/Ft Worth (DFW,DAL)-Pensacola (PNS)
Dallas/Ft Worth (DFW,DAL)-Palm Springs (PSP)
Dallas/Ft Worth (DFW,DAL)-Rapid City (RAP)
Dallas/Ft Worth (DFW,DAL)-Durham (RDU)
Dallas/Ft Worth (DFW,DAL)-Richmond, VA (RIC)
Dallas/Ft Worth (DFW,DAL)-Reno (RNO)
Dallas/Ft Worth (DFW,DAL)-Roswell (ROW)
Dallas/Ft Worth (DFW,DAL)-Ft Myers (RSW)
Dallas/Ft Worth (DFW,DAL)-Santa Fe (SAF)
Dallas/Ft Worth (DFW,DAL)-San Diego (SAN)
Dallas/Ft Worth (DFW,DAL)-Savannah (SAV)
Dallas/Ft Worth (DFW,DAL)-Louisville (SDF)
Dallas/Ft Worth (DFW,DAL)-Springfield, MO (SGF)
Dallas/Ft Worth (DFW,DAL)-Shreveport (SHV)
Dallas/Ft Worth (DFW,DAL)-San Angelo (SJT)
Dallas/Ft Worth (DFW,DAL)-San Juan, PR (SJU)
Dallas/Ft Worth (DFW,DAL)-Sacramento (SMF)
Dallas/Ft Worth (DFW,DAL)-Wichita Falls (SPS)
Dallas/Ft Worth (DFW,DAL)-Tallahassee (TLH)
Dallas/Ft Worth (DFW,DAL)-Tampa (TPA)
Dallas/Ft Worth (DFW,DAL)-Tulsa (TUL)
Dallas/Ft Worth (DFW,DAL)-Tucson (TUS)
Dallas/Ft Worth (DFW,DAL)-Texarkana (TXK)
Dallas/Ft Worth (DFW,DAL)-Tyler, TX (TYR)
Dallas/Ft Worth (DFW,DAL)-Knoxville (TYS)
Dallas/Ft Worth (DFW,DAL)-Valparaiso (VPS)
Dallas/Ft Worth (DFW,DAL)-Fayetteville, AR (XNA)
Vail/Eagle (EGE)-Chicago (ORD,MDW)
Vail/Eagle (EGE)-Dallas/Ft Worth (DFW,DAL)
Vail/Eagle (EGE)-Los Angeles (LAX,SNA,ONT,BUR,LGB)
Vail/Eagle (EGE)-Miami (MIA)
El Paso (ELP) -Dallas/Ft Worth (DFW,DAL)
Evansville, IN (EVV)-Chicago (ORD,MDW)
Evansville, IN (EVV)-Dallas/Ft Worth (DFW,DAL)
Key West (EYW)-Miami (MIA)
Fresno (FAT)-Dallas/Ft Worth (DFW,DAL)
Fayetteville, NC (FAY)-Dallas/Ft Worth (DFW,DAL)
37

App. 41

178.
179.
180.
181.
182.
183.
184.
185.
186.
187.
188.
189.
190.
191.
192.
193.
194.
195.
196.
197.
198.
199.
200.
201.
202.
203.
204.
205.
206.
207.
208.
209.
210.
211.
212.
213.
214.
215.
216.
217.
218.
219.
220.
221.
222.
223.

Ft Lauderdale (FLL)-Dallas/Ft Worth (DFW,DAL)
Flint (FNT)-Chicago (ORD,MDW)
Sioux Falls (FSD)-Dallas/Ft Worth (DFW,DAL)
Ft Smith, AR (FSM)-Dallas/Ft Worth (DFW,DAL)
Ft Wayne (FWA)-Dallas/Ft Worth (DFW,DAL)
Longview, TX (GGG)-Dallas/Ft Worth (DFW,DAL)
Grand Junction (GJT)-Dallas/Ft Worth (DFW,DAL)
Gainesville (GNV)-Miami (MIA)
Gulfport (GPT)-Dallas/Ft Worth (DFW,DAL)
Green Bay (GRB)-Marquette, MI (SAW)
Killeen (GRK)-Dallas/Ft Worth (DFW,DAL)
Grand Rapids (GRR)-Dallas/Ft Worth (DFW,DAL)
Greensboro, NC (GSO)-Dallas/Ft Worth (DFW,DAL)
Greensboro, NC (GSO)-Miami (MIA)
Greenville, SC (GSP)-Dallas/Ft Worth (DFW,DAL)
Gunnison (GUC)-Dallas/Ft Worth (DFW,DAL)
Hayden, CO (HDN)-Dallas/Ft Worth (DFW,DAL)
Honolulu (HNL)-Dallas/Ft Worth (DFW,DAL)
Huntsville, AL (HSV)-Dallas/Ft Worth (DFW,DAL)
Wichita (ICT)-Dallas/Ft Worth (DFW,DAL)
Wichita (ICT)-St Louis (STL)
Indianapolis (IND)-Dallas/Ft Worth (DFW,DAL)
Indianapolis (IND)-Miami (MIA)
Indianapolis (IND)-St Louis (STL)
Jackson, WY (JAC)-Dallas/Ft Worth (DFW,DAL)
Jackson, MS (JAN)-Dallas/Ft Worth (DFW,DAL)
Jacksonville (JAX)-Dallas/Ft Worth (DFW,DAL)
Jacksonville (JAX)-Miami (MIA)
Jacksonville (JAX)-St Louis (STL)
Las Vegas (LAS)-Miami (MIA)
Lawton, OK (LAW)-Dallas/Ft Worth (DFW,DAL)
Lubbock (LBB)-Dallas/Ft Worth (DFW,DAL)
Lake Charles (LCH)-Dallas/Ft Worth (DFW,DAL)
Lexington (LEX)-Dallas/Ft Worth (DFW,DAL)
Lafayette, LA (LFT)-Dallas/Ft Worth (DFW,DAL)
Little Rock (LIT)-Dallas/Ft Worth (DFW,DAL)
Laredo (LRD)-Dallas/Ft Worth (DFW,DAL)
La Crosse (LSE)-Chicago (ORD,MDW)
Los Angeles (LAX,SNA,ONT,BUR,LGB)-Vail/Eagle (EGE)
Los Angeles (LAX,SNA,ONT,BUR,LGB)-Roswell (ROW)
Los Angeles (LAX,SNA,ONT,BUR,LGB)-Santa Fe (SAF)
Los Angeles (LAX,SNA,ONT,BUR,LGB)-San Juan, PR (SJU)
Midland (MAF)-Dallas/Ft Worth (DFW,DAL)
McAllen (MFE)-Dallas/Ft Worth (DFW,DAL)
Montgomery (MGM)-Dallas/Ft Worth (DFW,DAL)
Manhattan, KS (MHK)-Chicago (ORD,MDW)
38

App. 42

224.
225.
226.
227.
228.
229.
230.
231.
232.
233.
234.
235.
236.
237.
238.
239.
240.
241.
242.
243.
244.
245.
246.
247.
248.
249.
250.
251.
252.
253.
254.
255.
256.
257.
258.
259.
260.
261.
262.
263.
264.
265.
266.
267.
268.
269.

Manhattan, KS (MHK)-Dallas/Ft Worth (DFW,DAL)
Miami (MIA)-Hartford (BDL)
Miami (MIA)-Birmingham (BHM)
Miami (MIA)-Nashville (BNA)
Miami (MIA)-Boston (BOS)
Miami (MIA)-Charleston, SC (CHS)
Miami (MIA)-Columbus, OH (CMH)
Miami (MIA)-Dallas/Ft Worth (DFW,DAL)
Miami (MIA)-Vail/Eagle (EGE)
Miami (MIA)-Key West (EYW)
Miami (MIA)-Gainesville (GNV)
Miami (MIA)-Greensboro, NC (GSO)
Miami (MIA)-Indianapolis (IND)
Miami (MIA)-Jacksonville (JAX)
Miami (MIA)-Las Vegas (LAS)
Miami (MIA)-New Orleans (MSY)
Miami (MIA)-Norfolk (ORF)
Miami (MIA)-Phoenix (PHX)
Miami (MIA)-Pittsburgh (PIT)
Miami (MIA)-Pensacola (PNS)
Miami (MIA)-Richmond, VA (RIC)
Miami (MIA)-Ft Myers (RSW)
Miami (MIA)-Savannah (SAV)
Miami (MIA)-Louisville (SDF)
Miami (MIA)-San Juan, PR (SJU)
Miami (MIA)-St Louis (STL)
Miami (MIA)-St Thomas Island (STT)
Miami (MIA)-St Croix Island (STX)
Miami (MIA)-San Fran (SFO,SJC,OAK)
Miami (MIA)-Tallahassee (TLH)
Miami (MIA)-Tulsa (TUL)
Miami (MIA)-Knoxville (TYS)
Milwaukee (MKE)-Marquette, MI (SAW)
Moline (MLI)-Dallas/Ft Worth (DFW,DAL)
Monroe, LA (MLU)-Dallas/Ft Worth (DFW,DAL)
Mobile (MOB)-Dallas/Ft Worth (DFW,DAL)
Marquette, MI (SAW)-Chicago (ORD,MDW)
Marquette, MI (SAW)-Green Bay (GRB)
Marquette, MI (SAW)-Milwaukee (MKE)
Marquette, MI (SAW)-Traverse City (TVC)
Madison (MSN)-Dallas/Ft Worth (DFW,DAL)
Madison (MSN)-St Louis (STL)
New Orleans (MSY)-Dallas/Ft Worth (DFW,DAL)
New Orleans (MSY)-Miami (MIA)
Montrose (MTJ) -Dallas/Ft Worth (DFW,DAL)
Myrtle Beach (MYR)-Dallas/Ft Worth (DFW,DAL)
39

App. 43

270.
271.
272.
273.
274.
275.
276.
277.
278.
279.
280.
281.
282.
283.
284.
285.
286.
287.
288.
289.
290.
291.
292.
293.
294.
295.
296.
297.
298.
299.
300.
301.
302.
303.
304.
305.
306.
307.
308.
309.
310.
311.
312.
313.
314.
315.

NYC (LGA,EWR,JFK)-Charleston (CRW)
NYC (LGA,EWR,JFK)-Fayetteville, AR (XNA)
Kahului, HI (OGG)-Dallas/Ft Worth (DFW,DAL)
Oklahoma City (OKC)-Dallas/Ft Worth (DFW,DAL)
Omaha (OMA)-Dallas/Ft Worth (DFW,DAL)
Norfolk (ORF)-Dallas/Ft Worth (DFW,DAL)
Norfolk (ORF)-Miami (MIA)
Norfolk (ORF)-St Louis (STL)
West Palm Beach (PBI)-Chicago (ORD,MDW)
West Palm Beach (PBI)-Dallas/Ft Worth (DFW,DAL)
Portland, OR (PDX)-Dallas/Ft Worth (DFW,DAL)
Phoenix (PHX)-Miami (MIA)
Peoria (PIA)-Dallas/Ft Worth (DFW,DAL)
Pittsburgh (PIT)-Dallas/Ft Worth (DFW,DAL)
Pittsburgh (PIT)-Miami (MIA)
Pensacola (PNS)-Dallas/Ft Worth (DFW,DAL)
Pensacola (PNS)-Miami (MIA)
Palm Springs (PSP)-Dallas/Ft Worth (DFW,DAL)
Rapid City (RAP)-Dallas/Ft Worth (DFW,DAL)
Durham (RDU)-Dallas/Ft Worth (DFW,DAL)
Richmond, VA (RIC)-Dallas/Ft Worth (DFW,DAL)
Richmond, VA (RIC)-Miami (MIA)
Richmond, VA (RIC)-St Louis (STL)
Reno (RNO)-Chicago (ORD,MDW)
Reno (RNO)-Dallas/Ft Worth (DFW,DAL)
Roswell (ROW)-Dallas/Ft Worth (DFW,DAL)
Roswell (ROW)-Los Angeles (LAX,SNA,ONT,BUR,LGB)
Rochester (RST)-Chicago (ORD,MDW)
Ft Myers (RSW)-Dallas/Ft Worth (DFW,DAL)
Ft Myers (RSW)-Miami (MIA)
Santa Fe (SAF)-Dallas/Ft Worth (DFW,DAL)
Santa Fe (SAF)-Los Angeles (LAX,SNA,ONT,BUR,LGB)
San Diego (SAN)-Dallas/Ft Worth (DFW,DAL)
San Antonio (SAT)-St Louis (STL)
Savannah (SAV)-Dallas/Ft Worth (DFW,DAL)
Savannah (SAV)-Miami (MIA)
Louisville (SDF)-Dallas/Ft Worth (DFW,DAL)
Louisville (SDF)-Miami (MIA)
Springfield, MO (SGF)-Dallas/Ft Worth (DFW,DAL)
Shreveport (SHV)-Dallas/Ft Worth (DFW,DAL)
San Angelo (SJT)-Dallas/Ft Worth (DFW,DAL)
San Juan, PR (SJU)-Hartford (BDL)
San Juan, PR (SJU)-Dallas/Ft Worth (DFW,DAL)
San Juan, PR (SJU)-Los Angeles (LAX,SNA,ONT,BUR,LGB)
San Juan, PR (SJU)-Miami (MIA)
San Juan, PR (SJU)-Tampa (TPA)
40

App. 44

316.
317.
318.
319.
320.
321.
322.
323.
324.
325.
326.
327.
328.
329.
330.
331.
332.
333.
334.
335.
336.
337.
338.
339.
340.
341.
342.
343.
344.
345.
346.
347.
348.

Sacramento (SMF)-Dallas/Ft Worth (DFW,DAL)
Wichita Falls (SPS)-Dallas/Ft Worth (DFW,DAL)
St Louis (STL)-Austin (AUS)
St Louis (STL)-Des Moines (DSM)
St Louis (STL)-Wichita (ICT)
St Louis (STL)-Indianapolis (IND)
St Louis (STL)-Jacksonville (JAX)
St Louis (STL)-Miami (MIA)
St Louis (STL)-Madison (MSN)
St Louis (STL)-Norfolk (ORF)
St Louis (STL)-Richmond, VA (RIC)
St Louis (STL)-San Antonio (SAT)
St Thomas Island (STT)-Miami (MIA)
St Croix Island (STX)-Miami (MIA)
San Fran (SFO,SJC,OAK)-Miami (MIA)
Tallahassee (TLH)-Dallas/Ft Worth (DFW,DAL)
Tallahassee (TLH)-Miami (MIA)
Toledo (TOL)-Chicago (ORD,MDW)
Tampa (TPA)-Dallas/Ft Worth (DFW,DAL)
Tampa (TPA)-San Juan, PR (SJU)
Bristol (TRI)-Chicago (ORD,MDW)
Tulsa (TUL)-Dallas/Ft Worth (DFW,DAL)
Tulsa (TUL)-Miami (MIA)
Tucson (TUS)-Chicago (ORD,MDW)
Tucson (TUS)-Dallas/Ft Worth (DFW,DAL)
Traverse City (TVC)-Marquette, MI (SAW)
Texarkana (TXK)-Dallas/Ft Worth (DFW,DAL)
Tyler, TX (TYR)-Dallas/Ft Worth (DFW,DAL)
Knoxville (TYS)-Dallas/Ft Worth (DFW,DAL)
Knoxville (TYS)-Miami (MIA)
Valparaiso (VPS)-Dallas/Ft Worth (DFW,DAL)
Fayetteville, AR (XNA)-Dallas/Ft Worth (DFW,DAL)
Fayetteville, AR (XNA)-NYC (LGA,EWR,JFK)

41

App. 45

U.S. Domestic City Pairs (Origin-Destination) in which AA
had 70-99% of non-stop seats in 2010
1. Miami (MIA)-Los Angeles (LAX,SNA,ONT,BUR,LGB)
2. Los Angeles (LAX,SNA,ONT,BUR,LGB)-Miami (MIA)
3. Miami (MIA)-Durham (RDU)
4. Durham (RDU)-Miami (MIA)
5. Los Angeles (LAX,SNA,ONT,BUR,LGB)-Dallas/Ft Worth (DFW,DAL)
6. Dallas/Ft Worth (DFW,DAL)-Los Angeles (LAX,SNA,ONT,BUR,LGB)
7. Miami (MIA)-Orlando (MCO)
8. Orlando (MCO)-Miami (MIA)
9. Boston (BOS)-St Thomas Island (STT)
10. St Thomas Island (STT)-Boston (BOS)
11. Dallas/Ft Worth (DFW,DAL)-Orlando (MCO)
12. Orlando (MCO)-Dallas/Ft Worth (DFW,DAL)
13. Miami (MIA)-Tampa (TPA)
14. Tampa (TPA)-Miami (MIA)
15. Dallas/Ft Worth (DFW,DAL)-San Fran (SFO,SJC,OAK)
16. San Fran (SFO,SJC,OAK)-Dallas/Ft Worth (DFW,DAL)
17. Miami (MIA)-Chicago (ORD,MDW)
18. Chicago (ORD,MDW)-Miami (MIA)
19. Palm Springs (PSP)-Chicago (ORD,MDW)
20. Wash DC (DCA,IAD,BWI)-Dallas/Ft Worth (DFW,DAL)
21. Dallas/Ft Worth (DFW,DAL)-Wash DC (DCA,IAD,BWI)
22. Chicago (ORD,MDW)-Palm Springs (PSP)
23. Miami (MIA)-Wash DC (DCA,IAD,BWI)
24. Wash DC (DCA,IAD,BWI)-Miami (MIA)
25. San Juan, PR (SJU)-St Croix Island (STX)
26. St Croix Island (STX)-San Juan, PR (SJU)
27. NYC (LGA,EWR,JFK)-Dallas/Ft Worth (DFW,DAL)
28. Dallas/Ft Worth (DFW,DAL)-NYC (LGA,EWR,JFK)
29. Las Vegas (LAS)-Dallas/Ft Worth (DFW,DAL)
30. Dallas/Ft Worth (DFW,DAL)-Las Vegas (LAS)
31. Chicago (ORD,MDW)-Dallas/Ft Worth (DFW,DAL)
32. Nashville (BNA)-NYC (LGA,EWR,JFK)
33. NYC (LGA,EWR,JFK)-Nashville (BNA)
34. Dallas/Ft Worth (DFW,DAL)-Chicago (ORD,MDW)
35. Los Angeles (LAX,SNA,ONT,BUR,LGB)-St Louis (STL)
36. Albuquerque (ABQ)-Chicago (ORD,MDW)
37. Chicago (ORD,MDW)-Albuquerque (ABQ)
38. Dallas/Ft Worth (DFW,DAL)-Seattle (SEA)
39. Seattle (SEA)-Dallas/Ft Worth (DFW,DAL)
40. Denver (DEN)-Miami (MIA)
41. St Louis (STL)-Los Angeles (LAX,SNA,ONT,BUR,LGB)
42. NYC (LGA,EWR,JFK)-Miami (MIA)
43. Miami (MIA)-NYC (LGA,EWR,JFK)
42

App. 46

44. Miami (MIA)-Denver (DEN)
45. Dallas/Ft Worth (DFW,DAL)-Memphis (MEM)
46. NYC (LGA,EWR,JFK)-St Thomas Island (STT)
47. St Thomas Island (STT)-NYC (LGA,EWR,JFK)
48. San Juan, PR (SJU)-St Thomas Island (STT)
49. Fayetteville, AR (XNA)-Chicago (ORD,MDW)
50. Chicago (ORD,MDW)-Fayetteville, AR (XNA)
51. Memphis (MEM)-Dallas/Ft Worth (DFW,DAL)

43

App. 47

U.S. to Asia and Asia to U.S. City Pairs (Origin-Destination) in which AA had
100% of non-stop flights in 2010
1. Tokyo, Japan (NRT)-Dallas-Ft Worth (DFW)
2. Dallas-Ft Worth (DFW)-Tokyo, Japan (NRT)
U.S. to Central America and Central America to U.S. City Pairs (Origin-Destination)
in which AA had 100% of non-stop flights in 2010
1. Beliz City, Beliz (BZE)-Dallas-Ft Worth (DFW)
2. Beliz City, Beliz (BZE)-Miami (MIA)
3. Guatemala City, Guatemala (GUA)-Dallas-Ft Worth (DFW)
4. Liberia, Costa Rica (LIR)-Dallas-Ft Worth (DFW)
5. Liberia, Costa Rica (LIR)-Miami (MIA)
6. Panama City, Panama (PTY)-Dallas-Ft Worth (DFW)
7. San Jose, Costa Rica (SJO)-Dallas-Ft Worth (DFW)
8. Dallas-Ft Worth (DFW)-Beliz City, Beliz (BZE)
9. Dallas-Ft Worth (DFW)-Guatemala City, Guatemala (GUA)
10. Dallas-Ft Worth (DFW)-Liberia, Costa Rica (LIR)
11. Dallas-Ft Worth (DFW)-Panama City, Panama (PTY)
12. Dallas-Ft Worth (DFW)-San Jose, Costa Rica (SJO)
13. Miami (MIA)-Beliz City, Beliz (BZE)
14. Miami (MIA)-Liberia, Costa Rica (LIR)
U.S. to Europe and Europe to U.S. City Pairs (Origin-Destination)
in which AA had 100 % of non-stop flights in 2010
1.
2.
3.
4.
5.
6.
7.
8.

Paris, France (CDG)-Dallas-Ft Worth (DFW)
London, England (LHR)-Raleigh-Durham, North Carolina (RDU)
Madrid, Spain (MAD)-Dallas-Ft Worth (DFW)
Manchester, England (MAN)-Chicago (ORD)
Dallas-Ft Worth (DFW)-Paris, France (CDG)
Dallas-Ft Worth (DFW)-Madrid, Spain (MAD)
Chicago (ORD)-Manchester, England (MAN)
Raleigh-Durham, North Carolina (RDU)-London, England (LHR)
U.S. to Canada/Mexico and Canada/Mexico to U.S. City Pairs (Origin-Destination)
in which AA had 100 % of non-stop flights in 2010

1.
2.
3.
4.

Acapulco, Mexico (ACA)-Dallas-Ft Worth (DFW)
Acapulco, Mexico (ACA)-Chicago (ORD)
Aguascalientes, Mexico (AGU)-Dallas-Ft Worth (DFW)
Leon, Mexico (BJX)-Dallas-Ft Worth (DFW)

44

App. 48

5. Chihuahua, Mexico (CUU)-Dallas-Ft Worth (DFW)
6. Dallas-Ft Worth (DFW)-Acapulco, Mexico (ACA)
7. Dallas-Ft Worth (DFW)-Aguascalientes, Mexico (AGU)
8. Dallas-Ft Worth (DFW)-Leon, Mexico (BJX)
9. Dallas-Ft Worth (DFW)-Chihuahua, Mexico (CUU)
10. Dallas-Ft Worth (DFW)-Guadalajara, Mexico (GDL)
11. Dallas-Ft Worth (DFW)-Monterrey, Mexico (MTY)
12. Dallas-Ft Worth (DFW)-Puerto Vallarta, Mexico (PVR)
13. Dallas-Ft Worth (DFW)-San Jose del Cabo, Mexico (SJD)
14. Dallas-Ft Worth (DFW)-San Luis Potosi, Mexico (SLP)
15. Dallas-Ft Worth (DFW)-Torreon, Mexico (TRC)
16. Dallas-Ft Worth (DFW)-Montreal, Canada (YUL)
17. Dallas-Ft Worth (DFW)-Vancouver, Canada (YVR)
18. Dallas-Ft Worth (DFW)-Calgary, Canada (YYC)
19. Dallas-Ft Worth (DFW)-Ixtapa/Zihuatanejo, Mexico (ZIH)
20. Guadalajara, Mexico (GDL)-Dallas-Ft Worth (DFW)
21. Monterrey, Mexico (MTY)-Dallas-Ft Worth (DFW)
22. Chicago (ORD)-Acapulco, Mexico (ACA)
23. Puerto Vallarta, Mexico (PVR)-Dallas-Ft Worth (DFW)
24. San Jose del Cabo, Mexico (SJD)-Dallas-Ft Worth (DFW)
25. San Luis Potosi, Mexico (SLP)-Dallas-Ft Worth (DFW)
26. Torreon, Mexico (TRC)-Dallas-Ft Worth (DFW)
27. Montreal, Canada (YUL)-Dallas-Ft Worth (DFW)
28. Vancouver, Canada (YVR)-Dallas-Ft Worth (DFW)
29. Calgary, Canada (YYC)-Dallas-Ft Worth (DFW)
30. Ixtapa/Zihuatanejo, Mexico (ZIH)-Dallas-Ft Worth (DFW)
U.S. to South America and South America to U.S. City Pairs (Origin-Destination)
in which AA had 100% of non-stop flights in 2010
1. Dallas-Ft Worth (DFW)-Caracas, Venezuela (CCS)
2. Dallas-Ft Worth (DFW)-Buenos Aires, Argentina (EZE)
3. Dallas-Ft Worth (DFW)-Rio de Janeiro, Brazil (GIG)
4. Dallas-Ft Worth (DFW)-Sao Paolo, Brazil (GRU)
5. Dallas-Ft Worth (DFW)-Santiago, Chile (SCL)
6. NYC (JFK)-Caracas, Venezuela (CCS)
7. NYC (JFK)-Buenos Aires, Argentina (EZE)
8. Miami (MIA)-La Paz, Bolivia (LPB)
9. Miami (MIA)-Maracaibo, Venezuela (MAR)
10. Miami (MIA)-Montevideo, Uruguay (MVD)
11. Caracas, Venezuela (CCS)-Dallas-Ft Worth (DFW)
12. Caracas, Venezuela (CCS)-NYC (JFK)
13. Buenos Aires, Argentina (EZE)-Dallas-Ft Worth (DFW)
14. Buenos Aires, Argentina (EZE)-NYC (JFK)

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15. Rio de Janeiro, Brazil (GIG)-Dallas-Ft Worth (DFW)
16. Sao Paolo, Brazil (GRU)-Dallas-Ft Worth (DFW)
17. Maracaibo, Venezuela (MAR)-Miami (MIA)
18. Montevideo, Uruguay (MVD)-Miami (MIA)
19. Recife, Brazil (REC)-Miami (MIA)
20. Santiago, Chile (SCL)-Dallas-Ft Worth (DFW)
U.S. to Asia and Asia to U.S. City Pairs (Origin-Destination) in which AA had
70-99% of non-stop seats in 2010
1. New Delhi, India (DEL)-Chicago (ORD)
2. Chicago (ORD)-New Delhi, India (DEL)
U.S. to Central America and Central America to U.S. City Pairs (Origin-Destination)
in which AA had 70-99% of non-stop seats in 2010
1.
2.
3.
4.
5.

Tegulcigapa, Honduras (TGU)-Miami (MIA)
San Jose, Costa Rica (SJO)-Miami (MIA)
Guatemala City, Guatemala (GUA)-Miami (MIA)
Miami (MIA)-Tegulcigapa, Honduras (TGU)
Miami (MIA)-San Jose, Costa Rica (SJO)
6. Miami (MIA)-Guatemala City, Guatemala (GUA)
U.S. to Europe and Europe to U.S. City Pairs (Origin-Destination)
in which AA had 70-99% of non-stop seats in 2010

1. London, England (LHR)-Dallas-Ft Worth (DFW)
2. Dallas-Ft Worth (DFW)-London, England (LHR)
U.S. to Canada/Mexico and Canada/Mexico to U.S. City Pairs (Origin-Destination)
in which AA had 70-99% of non-stop seats in 2010
1. Miami (MIA)-Montreal, Canada (YUL)
2. Montreal, Canada (YUL)-Miami (MIA)
3. Cozumel, Mexico (CZM)-Dallas-Ft Worth (DFW)
4. Dallas-Ft Worth (DFW)-Cozumel, Mexico (CZM)
5. San Jose del Cabo, Mexico (SJD)-Chicago (ORD)
6. Cancun, Mexico (CUN)-Dallas-Ft Worth (DFW)
7. Dallas-Ft Worth (DFW)-Cancun, Mexico (CUN)
8. Chicago (ORD)-San Jose del Cabo, Mexico (SJD)
9. Dallas-Ft Worth (DFW)-Mexico City, Mexico (MEX)
10. Mexico City, Mexico (MEX)-Dallas-Ft Worth (DFW)
11. Miami (MIA)-Cancun, Mexico (CUN)
12. NYC (JFK)-Halifax, Canada (YHZ)

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13. Halifax, Canada (YHZ)-NYC (JFK)
14. Cancun, Mexico (CUN)-Miami (MIA)
U.S. to South America and South America to U.S. City Pairs (Origin-Destination)
in which AA had 70-99% of non-stop seats in 2010
1.
2.
3.
4.
5.
6.

Miami (MIA)-Salvador, Brazil (SSA)
Miami (MIA)-Belo Horizonte, Brazil (CNF)
Miami (MIA)-Guayaquil, Ecuador (GYE)
Belo Horizonte, Brazil (CNF)-Miami (MIA)
Guayaquil, Ecuador (GYE)-Miami (MIA)
Santa Cruz, Bolivia (VVI)-Miami (MIA)

47

App. 51

U.S. to Caribbean City Pairs (Origin-Destination) in which AA had
100% of non-stop flights in 2010
1. Dallas-Ft Worth (DFW)-Bridgetown, Barbados (BGI)
2. Dallas-Ft Worth (DFW)-Montego Bay, Jamaica (MBJ)
3. Dallas-Ft Worth (DFW)-Providenciales, Bahamas (PLS)
4. NYC (JFK)-Providenciales, Bahamas (PLS)
5. NYC (JFK)-Basseterre, St Kitts (SKB)
6. Miami (MIA)-St Johns, Antigua (ANU)
7. Miami (MIA)-St George, Bermuda (BDA)
8. Miami (MIA)-Bridgetown, Barbados (BGI)
9. Miami (MIA)-Freeport, Bahamas (FPO)
10. Miami (MIA)-Georgetown, Bahamas (GGT)
11. Miami (MIA)-St George, Grenada (GND)
12. Miami (MIA)-Kingston, Jamaica (KIN)
13. Miami (MIA)-La Romana, Dominican Republic (LRM)
14. Miami (MIA)-Montego Bay, Jamaica (MBJ)
15. Miami (MIA)-Marsh Harbor, Bahamas (MHH)
16. Miami (MIA)-Providenciales, Bahamas (PLS)
17. Miami (MIA)-Puerto Plata, Dominican Republic (POP)
18. Miami (MIA)-Basseterre, St Kitts (SKB)
19. Miami (MIA)-Santiago, Dominican Republic (STI)
20. Miami (MIA)-Philipsburg/St Maarten, Netherlands Antilles (SXM)
21. Miami (MIA)-Treasure Cay, Bahamas (TCB)
22. Miami (MIA)-St Lucia (UVF)
Caribbean to U.S. City Pairs (Origin-Destination) in which AA had
100% of non-stop flights in 2010
1. St Johns, Antigua (ANU)-Miami (MIA)
2. St George, Bermuda (BDA)-Miami (MIA)
3. Bridgetown, Barbados (BGI)-Dallas-Ft Worth (DFW)
4. Bridgetown, Barbados (BGI)-Miami (MIA)
5. Freeport, Bahamas (FPO)-Miami (MIA)
6. Georgetown, Bahamas (GGT)-Miami (MIA)
7. St George, Grenada (GND)-Miami (MIA)
8. Kingston, Jamaica (KIN)-Miami (MIA)
9. La Romana, Dominican Republic (LRM)-Miami (MIA)
10. Montego Bay, Jamaica (MBJ)-Dallas-Ft Worth (DFW)
11. Montego Bay, Jamaica (MBJ)-Miami (MIA)
12. Marsh Harbor, Bahamas (MHH)-Miami (MIA)
13. Providenciales, Bahamas (PLS)-Dallas-Ft Worth (DFW)
14. Providenciales, Bahamas (PLS)-NYC (JFK)
15. Providenciales, Bahamas (PLS)-Miami (MIA)

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16. Puerto Plata, Dominican Republic (POP)-Miami (MIA)
17. Basseterre, St Kitts (SKB)-NYC (JFK)
18. Basseterre, St Kitts (SKB)-Miami (MIA)
19. Santiago, Dominican Republic (STI)-Miami (MIA)
20. Philipsburg/St Maarten, Netherlands Antilles (SXM)-Miami (MIA)
21. Treasure Cay, Bahamas (TCB)-Miami (MIA)
22. St Lucia (UVF)-Miami (MIA)
Caribbean to Caribbean City Pairs (Origin-Destination) in which AA had
100% of non-stop flights in 2010
1. Bridgetown, Barbados (BGI)-San Juan, PR (SJU)
2. Fort de France, Martinique (FDF)-San Juan, PR (SJU)
3. St George, Grenada (GND)-San Juan, PR (SJU)
4. La Romana, Dominican Republic (LRM)-San Juan, PR (SJU)
5. Nevis, St Kitts (NEV)-San Juan, PR (SJU)
6. Port Au Prince, Haiti (PAP)-San Juan, PR (SJU)
7. Port Au Prince, Haiti (PAP)-Santiago, Dominican Republic (STI)
8. Puerto Plata, Dominican Republic (POP)-San Juan, PR (SJU)
9. Port of Spain, Trinidad & Tobego (POS)-San Juan, PR (SJU)
10. Pointe-a-Pitre, Guadeloupe (PTP)-San Juan, PR (SJU)
11. Higuey, Dominican Republic (PUJ)-San Juan, PR (SJU)
12. San Juan, PR (SJU)-Bridgetown, Barbados (BGI)
13. San Juan, PR (SJU)-Dominica, Dominica (DOM)
14. San Juan, PR (SJU)-Fort de France, Martinique (FDF)
15. San Juan, PR (SJU)-St George, Grenada (GND)
16. San Juan, PR (SJU)-La Romana, Dominican Republic (LRM)
17. San Juan, PR (SJU)-Nevis, St Kitts (NEV)
18. San Juan, PR (SJU)-Port Au Prince, Haiti (PAP)
19. San Juan, PR (SJU)-Puerto Plata, Dominican Republic (POP)
20. San Juan, PR (SJU)-Port of Spain, Trinidad & Tobego (POS)
21. San Juan, PR (SJU)-Higuey, Dominican Republic (PUJ)
22. San Juan, PR (SJU)-Basseterre, St Kitts (SKB)
23. San Juan, PR (SJU)-Santiago, Dominican Republic (STI)
24. Santiago, Dominican Republic (STI)-San Juan, PR (SJU)
25. Santiago, Dominican Republic (STI)-Port Au Prince, Haiti (PAP)
Caribbean to South American and South America to Caribbean City Pairs (Origin-Destination) in
which AA had 100% of non-stop flights in 2010
1. San Juan, PR (SJU)-Caracas, Venezuela (CCS)
2. Caracas, Venezuela (CCS)-San Juan, PR (SJU)

49

App. 53

U.S. to Caribbean City Pairs (Origin-Destination) in which AA had
70-99% of non-stop seats in 2010
1.
2.
3.
4.
5.
6.
7.
8.

Dallas-Ft Worth (DFW)-Nassau, Bahamas (NAS)
Miami (MIA)-Governors Harbour, Bahamas (GHB)
Miami (MIA)-Santo Domingo, Dominican Republic (SDQ)
Miami (MIA)-Aruba, Aruba (AUA)
Miami (MIA)-North Eleuthera, Bahamas (ELH)
Miami (MIA)-Higuey, Dominican Republic (PUJ)
Miami (MIA)-Port Au Prince, Haiti (PAP)
Miami (MIA)-Port of Spain, Trinidad & Tobego (POS)
Caribbean to U.S. City Pairs (Origin-Destination) in which AA had
70-99% of non-stop seats in 2010

1.
2.
3.
4.
5.
6.
7.
8.

Nassau, Bahamas (NAS)-Dallas-Ft Worth (DFW)
Governors Harbour, Bahamas (GHB)-Miami (MIA)
Santo Domingo, Dominican Republic (SDQ)-Miami (MIA)
Aruba, Aruba (AUA)-Miami (MIA)
North Eleuthera, Bahamas (ELH)-Miami (MIA)
Higuey, Dominican Republic (PUJ)-Miami (MIA)
Port Au Prince, Haiti (PAP)-Miami (MIA)
Port of Spain, Trinidad & Tobego (POS)-Miami (MIA)
Caribbean to Caribbean City Pairs (Origin-Destination) in which AA had
70-99% of non-stop seats in 2010

1.
2.
3.
4.
5.
6.
7.
8.

San Juan, PR (SJU)-Pointe-a-Pitre, Guadeloupe (PTP)
Dominica, Dominica (DOM)-San Juan, PR (SJU)
Anguilla, Anguilla (AXA)-San Juan, PR (SJU)
Basseterre, St Kitts (SKB)-San Juan, PR (SJU)
San Juan, PR (SJU)-Anguilla, Anguilla (AXA)
Castries, St Lucia (SLU)-San Juan, PR (SJU)
San Juan, PR (SJU)-Beef Island, British Virgin Islands (EIS)
Philipsburg/St Maarten, Netherlands Antilles (SXM)-San Juan, PR (SJU)

50

App. 54