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OST-2004-19214 - SkyTeam Antitrust - Indivual Comments
OST-2004-19214 - Joint Application for Antitrust Immunity
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Delta Air Lines, Inc. / KLM Royal Dutch Airlines / Northwest Airlines, Inc. / Societe Air France / Alitalia-Linee Aeree Italiane-S.p.A. / Czech Airlines
July 15, 2005 The reason that American has been so active in this proceeding is that a favorable outcome for the joint applicants will present American with a new situation it will be faced with not one but two competitors of a size and scope equal to its own, each of which will have antitrust immunity. Since American agrees with most analysts that size and scope matter in network competition, it and Oneworld will be faced with an excruciating dilemma whether to drop objections to other U.S. airline access to Heathrow and regain parity through antitrust immunity or insist on the advantages of protection while putting itself at a competitive disadvantage in all other markets touching the United States. This is the dilemma it is trying to escape by intervening in this proceeding. By: Michael Levine
July 19, 2005 I herby submit this docket in support of American Airlines' opposition towards granting anti-trust immunity between Northwest Airlines and other trans-Atlantic airlines. These steps would be very unfair and anticompetitive for the industry. It puzzles me that the proposed British Airways/American Airlines anti-trust proposal continues to be rejected, while one to further strengthen an already powerful bond between the skyTeam airlines is being considered. Unless British Airways and American Airlines get their simple request for anti-trust immunity granted, I urge the DOT to reject any such proposals by Northwest, Alitalia, Air France, and other skyTeam airlines.
July 22, 2005
July 22, 2005
July 25, 2005
August 22, 2005 I oppose to the anti-trust immunity between the skyTeam airlines.
August 22, 2005 I am opposed to the proposed anti-trust immunity between the skyTeam airlines. It's unfair to give it to them while AA/BA can't get anti-trust immunity for flights between the US and UK.
August 22, 2006 I oppose to the proposed anti-trust immunity between the Skyleam airlines. It should be clear that if anti-trust immunity is granted to the airlines in the Skyleam alliance, it will provide an unfair advantage to the airlines when it comes to important transatlantic routes into Europe. This is the last thing the US airline industry needs right now, particularly when it comes to American Airlines, a member of the Oneworld Alliance.
August 22, 2005 I oppose to the proposed anit-trust immunity bewteen the skyTeam airlines.
August 22, 2005 I am in opposition of the proposed anti-trust immunity between the skyTeam airlines.
August 22, 2005 There are very good reasons for anti-trust/monopoly laws and regulatory frameworks. This is a wonderful example of why we need them, as it would place one consortium/cartel in an unjustifiable position of strength.
August 22, 2005 I strongly oppose any airline or airline alliance from have antitrust immunity. This is completely against the ideals of this country, free trade and capitalism. Giving a single alliance immunity basically gives them an unfair advantage over the other alliances. I believe it should be your duty to ensure a level playing field, not give any undue advantages. Competition must be protected for the sake of consumers and the public in general.
August 22, 2005 I oppose the proposed anti-trust immunity by Sky Team airlines. Anti-trust immunity would give two US and four European airlines an unfair majority of air traffic between the United States and Italy, France, Czech Republic and the Netherlands. Such operation removes traveler options and creates an imbalance among US-based airlines.
August 22, 2005 I oppose the anti-trust immunity for the SkyTeam airlines. I feel that this would reduce competition in the transatlantic market.
August 30, 2005 Surrebuttal of Daniel Kasper and Darin Lee - Bookmarked Comments filed by the Department of Justice make it clear that DOJ has not been persuaded by the claims of Brattle and American that granting ATI would reduce transatlantic competition. Nonetheless, in light of the important international aviation policy interests implicated by Brattle's comments, as well as DOT's independent statutory authority, we have responded in some detail to the claims put forward by Brattle and American. The remainder of this declaration is organized as follows. Section II addresses issues related to airfares, in particular, the appropriate use of the DOT's O&D survey data. Section III addresses issues raised by Brattle related to output. Section IV addresses issues related Brattle's analysis of interlining at CDG. Section V responds to the assertion by American that the joint applicants have misled the Department with regards to the number of new online city-pairs that would be created as a result of joint ATI as well as some of the concerns raised by the Department of Justice in their recently filed comments in this proceeding.
August 30, 2005 AA has provided one example of the GRR-JFK market where it asserts (but does not prove) the third condition above, that is, that passenger diversion would be high enough to alter Delta's capacity allocation decision. AA has provided no evidence that all of the above conditions are met for any relevant city-pair market, much less evidence that they are met in any significant number of such markets. Nor has AA quantified any harm to consumers in any relevant markets based on this theory, or compared such harm to the offsetting benefits on other routes to which capacity is reallocated. Without such a showing, there is no basis to conclude that any of the "unilateral" effects hypothesized by AA would be anti-competitive, even if they were to arise.
August 30, 2005 Supplemental Statement of Timothy Muris on Behalf of Northwest Airlines Of the dozens of private parties who commented to DOT, only a competitor, American Airlines, is opposed. The louder a competitor complains, the more likely such complaints indicate that a practice will make life harder for the competitor because it will increase competition, not decrease it. DOJ confirms that this is the case here, concluding that the expanded ATI will not decrease transatlantic competition and will benefit consumers. Given the “continuing applicability of the antitrust laws” to domestic conduct, DOJ Comments at 37, and the clear record that transatlantic competition will not be reduced, id. at 2, 15, there is every reason to grant ATI and allow Northwest and Delta to participate fully in a competitive international alliance. At most, DOT should follow DOJ’s recommendations that ATI be granted conditionally.
December 23, 2005 Opposition Comments of David Buckholtz By: David Buckholtz
December 23, 2005 Opposition Comments of Casey Haney By: Casey Haney
December 23, 2005 Opposition Comments of Steve Janzen By: Steve Janzen
December 25, 2005 Opposition Comments of John Northcut By: John Northcut |
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