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OST-95-347

Continental Airlines, Inc. and Alitalia-Linee Aeree Italiane-S.p.A.

OST-95-348 OST-95-347 OST-97-2113 Undocketed	September 24, 1998	Joint Application for Renewal of Exemptions and Statements of Authorization	Newark, New Jersey - Houston, Rome, Italy - Milan, Italy
		Service List

Counsel: Crowell Moring LLP, R. Bruce Keiner, Jr., rbkeiner@cromor.com

Continental Airlines, Inc. / Alitalia-Linee Aeree Italiane-S.p.a.

OST-95-348 OST-95-347 OST-97-2113 Undocketed

October 8, 1998

Answer of United Air Lines to Joint Application for Renewal

Newark-Rome/Milan, Houston-Rome; Rome/Milan-Newark/Atlanta; Codesharing

United Air Lines, Inc. ("United") hereby answers the application of Alitalia-Linee Aeree Italiane-S.p.a ("Alitalia") and Continental Airlines, Inc. ("Continental") for renewal of various authorities granted them by exemptions in these dockets and by statements of authorization for code-sharing operations.

Counsel:  United and Kirkland Ellis, Jeffrey Manley, 202-879-5161, jeffrey_manley@kirkland.com

Continental Airlines, Inc. and Alitalia

OST-95-348 OST-95-347 OST-97-2113

October 7, 1998

Re:  Service List

Codeshare

Counsel:  Crowell Moring, Bruce Keiner, 202-624-2500

Continental Airlines, Inc. and Alitalia-Linee Aeree Italiane-S.p.A.

OST-95-348 OST-95-347 OST-97-2113 Undocketed

October 20, 1998

Joint Reply of Continental, Continental Express and Alitalia

Newark-Rome/Milan, Houston-Rome Rome/Milan-Newark/Atlanta

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The only extrabilateral element involved in the proposed code-share arrangement among Continental, Continental Express and Alitalia is the benefit to the U.S. of having Continental authorized to serve U.S.-Italy routes, including the Newark-Rome/Milan routes, that would otherwise be precluded under the U.S.-Italy aviation bilateral agreement. If the Department granted United's request to limit renewal of authority on these routes to a short term, it would be limiting extrabilateral benefits to the United States, Newark, Continental and the passengers and shippers Continental serves. That would not serve the public interest or promote U.S. objectives in maximizing the limited rights currently available between the U.S. and Italy. Instead, it would deprive the public of the substantial benefits that will result from the Department's grant of indefinite authority. The public should not be penalized because United and one of its codeshare partners, Lufthansa, do not have extrabilateral U.S.-Italy authority.

Counsel:  Zuckert Scoutt, Richard Mathias, 202-298-8660 for Alitalia / Continental and Crowell Moring, Bruce Keiner, 202-624-2615

Continental Airlines, Inc./Continental Express, Inc. and Alitalia-Linee Aeree Italiane-S.p.A.

By:  Paul Gretch

Continental Airlines, Inc.; Continental Express, Inc.; and Atitalia- Linee Aeree Italaine- S.p.A.

By:  Paul Gretch

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