NEW DISTRIBUTION CAPABILITY AND COMPETITION 603 to potential consumers, regardless of the platform used, is fair and accurate. That is fine, insofar as it goes, but surely someone on the Lufthansa website will expect to see Lufthansa flights. If Lufthansa, via the NDC, is then able to offer passengers services that are very much alike those provided by travel agents sitting in front of a GDS, with things like seat maps and special meals, is the 16.00€ surcharge appropriate? It looks like an attempt to exploit a market position. To which Lufthansa will note that there is plenty of airline competition out there. Should the Commission have a role in requiring that fares are presented in a fair way? The consumer best interest is in finding clear and accurate data on fares, but policing that in a world of unbundled fares and charges is going to be very time consuming. What role does DG MOVE have in a fight between large corporations that would normally be considered as part of DG COMP’s bailiwick? IATA is confident that there are no competition issues arising from that. The agents have their own view, as do the various suppliers of systems, both to the agents and to the public more directly. Everyone seems to be assuming that the putative passengers want full transparency. That is highly unlikely, given the plethora of options. Perhaps all they want is ease of access and some sort of assurance as to price range. Guaranteeing the lowest price is something that none of the systems is prepared to do. And the Internet economy moves on, leaving the airlines, IATA’s NDC, the GDSs and all the others looking like shareholders in a buggy-whip factory. New apps are being built to resolve the issue, but they need access to the data. Those apps show the airline the passengers’ identity, a dystopian future for the legacy travel agents. Nowadays, agents do not work for the airlines and they own the passenger data. Google, in the meantime, controls content targeting and owns a CRS. Its pricing model is free to the passengers and airlines. The purpose of the original code of conduct was to limit the airlines’ pre- -deregulation dominance in a liberalised world. It needs now to be changed to suit the new, new world. The Internet means that now there are some systems which are regulated and some that are not, some that are biased and some that are not, as well as some that discriminate by channel. Whatever comes out of any consultation needs to be technology and channel neutral and give consumers access to information, not the other way around.
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