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Case No. MUL-372-1
Airline Tariff Publishing Company
c/o [ ], Esq.
Cooley LLP
1299 Pennsylvania Ave., NW, Suite 700
Washington, D.C. 20004
Dear Mr. [ ]:
This responds to the request, dated April 14, 2011 (the “Request”), on behalf of Airline Tariff Publishing Company (the “Client”), to the Office of Foreign Assets Control (OFAC), requesting authorization to engage in certain transactions with airlines in Burma, Cuba, Iran, Sudan, and Libya (the “Sanctioned Countries”). According to the Request, the Client collects and distributes data related to airfare for airlines, online travel agents, global distributions systems, and computer reservation systems around the world. The Request states that the airline industry has designated the Client as its [ ] for many components of fare and fare-related data, and that the Client’s customers represent an estimated [ ] of...
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1) BACKGROUND
The Airline Tariff Publishing Company (ATPCO) is the primary entity, and possibly the only entity, that serves as a conduit between airlines and global distributions systems such as Sabre and large online travel agents, such as Travelocity. (See Sabre Corporation, 2019 10-K Filing, 2023 Q1 10-Q Filing), for information on Sabre's activities and their status as exempt).
In the first paragraph of the letter, OFAC recounts that APCO "collects fare data from and distributes passenger data to several airlines based in [sanctioned countries]," and that it "engages in these activities based on its understanding that certain exemptions from OFAC’s regulations may apply..."
See also https://www.atpco.net/legal/terms-of-use, explaining that ATPCO:
"collect[s] the fares and rules data instructed by airlines and distribute them to the GDSs, revenue management and revenue accounting systems, passenger...