Duff on Hospitality Law

Good Sunday evening from Seattle . . . Our weekly Online Travel Update for the week ending Friday, February 20, 2026, is below. Last week we featured stories on the reported AI activities of Marriott and Hyatt, and this week we feature updates on both Wyndham and IHG. This week’s Update also offers a few perspectives on Booking Holdings’ recent quarterly earnings release (a copy of the Booking Holdings’ earnings call transcript is also linked below). Enjoy.

• • Wyndham Partners with Google, Claude and OpenAI. What are major hotel suppliers doing to counter the seemingly endless AI announcements by the major OTA platforms? Wyndham CEO, Geoff Ballotti shared information on Wyndham’s plans in Wyndham’s recent earnings release call. According to Ballotti, Wyndham has partnered with Google (serving as one of Google initial integration AI mode partners), Claude (providing Claude direct access to Wyndham’s rates and inventory) and OpenAI (working to also provide ChatGPT direct access to Wyndham’s rates and inventory). So far, the costs associated with these efforts are minimal as both Claude and ChatGPT (which refer users back to the Wyndham website to complete the booking) are foregoing transaction costs – at least for now.
  • IHG Updates Its Hotel Content. According to IHG CEO, Elie Maalouf, IHG may not be as externally focused as its competitors (at least not yet) when it comes to transitioning for AI. In an earnings call last week, Maalouf, detailed the company’s plans to adopt an entirely new AI-compatible hotel content platform to better attract and respond to AI systems. IHG is also working with Google to develop AI trip planning capabilities that will allow for natural language searches on the IHG websites and apps. These AI specific updates are part of a larger technology overhaul by IHG that is currently underway and features the rollout of a new customer relationship management platform, guest reservation system and property management system – all of which are cloud based.
  • Booking Holdings Reports Strong 4Q and Full Year Results. A few takeaways from last week’s Booking Holdings’ earnings release and call:

    • Demand. Demand growth (9% YOY growth in 4Q) was driven by growth in the U.S. (10-12% YOY growth in 4Q).

    • Artificial Intelligence. Management was far more focused on the savings achieved via AI integration in its customer support processes (roughly 10% per booking) versus new customer acquisition. Management remains bullish on the important role that OTAs like Booking.com will serve in the post AI world as, according to Booking, AI platforms will ultimately serve largely search and advertising functions (and not as an actual merchant).

    • The Importance of Independent Hoteliers. Booking Holdings CEO, Glenn Fogel, spoke at length about the importance of Booking’s relationships with independent hotels and the value that Booking represents to this hotel segment. According to Fogel, the 10 largest hotel chains account for only a “low double digit percentage” of Booking.com’s total room bookings. Interesting timing for Booking to raise this point as AI and now Airbnb appear to present viable threats to Booking’s dominance of this hotel segment.

    • The Increasing Role of Connected Transactions. Connected transactions grew in the high 20% range in 2025. Connected transactions now represent a low double digit percentage of all Booking.com transactions. Note that Booking’s view of “connected transactions” is slightly different than the traditional “packages” definition in that Booking.com defines a connected transaction as one where one traveler books multiple travel verticals over a 1-3 day period (and not necessarily a simultaneous purchase of multiple verticals like most traditional packages).

    • Marketing. Booking invested heavily in marketing during 4Q (total marketing increased 22% YOY in 4Q) and throughout 2025 (total marketing increased 12%). During 2025, Booking Holdings invested a total of $8.1 billion dollars in marketing (let that number sink in), which represents 4.4% of Booking Holdings’ total gross booking value during the same period. Note that social media investments increased 13% during 4Q.

  • Booking.com Defends Contracting Practices. Ever wonder how Booking.com views the many investigations and class action claims brought against it over its allegedly anti-competitive contracting practices? Booking.com recently posted a response on its website.

  • Google Testing Ad Formats for AI Mode. Anyone surprised by this one? Last week, we included a story about ChatGPT’s announced commencement of ad testing on the lowest tiers of its AI subscriptions. Not to be outdone, Google has announced plans to begin testing new ad formats for retailers that offer products and services most responsive to a user’s natural language query. According to Google, similar tests are also being run in the travel industry. What these AI ads ultimately look like and just how personalized they may become – think loyalty – remains to be seen.

Have a great week everyone.

Good Sunday afternoon from Seattle . . . Our weekly Online Travel Update for the week ending Friday, February 13, 2026, is below. What started out as a quiet week in the online travel industry changed considerably as the week progressed. Earnings releases from the major lodging suppliers and Expedia garnered much of the week’s headlines. Enjoy.

• • Expedia Reports Solid Fourth Quarter Results – Led Again by Its B2B Offerings. Expedia released its fourth quarter and full year results this past week. Highlights from this past week’s release include the following:
    
    • B2C bookings remained relatively stable. Partner funded promotions represented 30% of the bookings mix in 4th quarter (up from 3rd quarter). All three of Expedia’s consumer brands (Expedia, Hotels.com and VRBO) saw growth in the 4th quarter.
    • Advertising revenue continues to grow, up 19% YOY for the 4th quarter.
    • B2B continues its consistently strong growth – gross bookings grew 24% YOY in the 4th quarter. B2B partner commissions were 61.6% of B2B revenue in 2025 (up from 60.7% in 2024). B2B continues to expand its product offerings with increased accommodations supply, new car rental connections and soon, experiences via Expedia’s recently announced acquisition of Tiqets.
    • Expedia’s comments regarding AI and its adoption and use across the platform’s many verticals remained largely unchanged from its most recent earnings release statement.

A transcript of Expedia’s quarterly earnings call is attached for those of you interested.

• • Hoteliers Share Approaches to AI Use in Marketing and Distribution. This past week saw Hyatt and Marriott offer glimpses into their respective AI efforts. According to Hyatt CEO, Mark Hoplamazian, Hyatt’s efforts are most readily apparent in search, as Hyatt has added natural language search to its website and recently launched a Hyatt branded app within ChatGPT’s app ecosystem. Like Accor’s previously announced app, the Hyatt app allows ChatGPT users to search rates and availability and then re-directs those users to Hyatt.com to complete the booking. According to Hoplamazian, Hyatt’s efforts with its own website are already producing positive results. According to Marriott CEO, Anthony Capuano, Marriott is working closely with Google to integrate with Google’s AI Mode that, according to Capuano, will deliver a “priority search experience” and allow bookings to “be processed through AI Mode.” What this integration might actually mean is still somewhat unknown. How will Marriott’s search experience differ from other major travel brands? Is Google reconsidering earlier comments that it does not intend to become an online travel agent? Will bookings actually be completed within Google AI or will users instead be referred to Marriott.com to complete the booking? As for ChatGPT, Capuano announced that Marriott would be participating in ChatGPT’s early advertising pilot (see story below). These latest announcements follow disclosures by both Hilton and Marriott in recent securities filings where both companies noted for the first time the risks posed by AI and possible disintermediation caused by AI, which could make even harder direct booking efforts and drive up the cost of distribution.
  • OpenAI Begins Testing Ads within ChatGPT. Late last month, we shared OpenAI’s plans to test advertisements for users of certain versions of ChatGPT. OpenAI announced this past week that the tests have begun in the U.S. for adult, logged-in users of ChatGPT’s Free and Go subscription tiers. In last week’s announcement, OpenAI reiterated some of the guiding principles behind the new advertising product, including commitments that advertising will not affect ChatGPT’s answers to users’ prompts and users’ conversations with ChatGPT will not be shared with advertisers. According to OpenAI, it will decide which ads to show to users based on the topic of users’ conversations, users’ past conversations and users’ past interactions with ads.
  • Malaysian Competition Authorities Flag OTA Parity Provisions as Part of Digital Economy Market Review. Following its 18 month review of OTAs and other similar online travel marketplaces (including metasearch sites), the Malaysian Competition Commission reported several central competition concerns including (i) rate parity, (ii) algorithmic ranking (and the effect that higher commissions might have on ranking), (iii) keyword bidding, (iv) OTAs extensive first-party data collection practices, (v) the potentially anti-competitive use of generative AI and (vi) a variety of consumer facing tactics – drip pricing, pressure-selling and misleading reviews. Sounds like my usual OTA contracting checklist. While the review does not constitute a decision by the Commission, it does serve to identify areas where the Commission may in the future adopt guidelines or pursue further engagements with market participants.

Have a great week everyone.

Good Sunday afternoon from Seattle . . . For those of you who follow American football, Happy Superbowl Sunday (apparently the number one sports betting day of the year). Our weekly Online Travel Update for the week ending Friday, February 6, 2026, is below. This week’s Update features a new story from the Technology Travel Association on state efforts to regulate technology pricing. I’ve also included an update on the much discussed collective action against Booking.com and offer further evidence as to why I believe Google will inevitably become the most widely used AI platform – even for travel. Enjoy.

• • Travel Technology Association Defeats Proposed Pricing Technology Legislation. You might ask why we are featuring a story this week on the Travel Technology Association’s successful defeat (at least for now) of proposed pricing technology legislation in Virginia. The story is only one of several important updates on pricing legislation that we received last week, including a detailed national overview of current state efforts to regulate the use of pricing technology by AH&LA’s Sarah Bratko. According to Sarah, 17 states have pricing legislation currently pending (not including already enacted legislation in California and New York). (So much for the Trump Administration’s attempt to restrict state-level regulation of AI.) If you’ve haven’t looked into this issue or its potential effects on your loyalty program or targeted promotions, I encourage you to do so. If you have questions, please let me know.
  • Siteminder Releases Annual Hotel Bookings Trend Report. This past week, Siteminder released its annual Hotel Bookings Trend report for 2025. Highlights in this year’s report include (a) revenue share among booking channels stayed relatively flat (95% of markets reported only a 1.5% change over last year), (b) AI and OTAs are gaining share on research, but directly bookings remain stable, (c) among available channels (direct, wholesale, GDS and OTA), bookings generated through direct bookings produced the highest value per booking ($516) and (d) by 2030, Asia will account for 3.5 billion middle class travelers – approximately two thirds of the global total.
  • Hoteliers File Collective Action Against Booking.com. For the past year, we have had stories about a possible collective action by European hoteliers against Booking.com over its allegedly anti-competitive contracting practices (namely, parity). This past week, the Dutch foundation representing the hotels formally initiated action before an Amsterdam Court. While “several thousand” hotels were part of this initial filing, Hotrec reports that extensions of the collective action will be brought later this year to add more hotels.
  • ChatGPT and Booking.com Launch SME AI Accelerator. While the majority of announcements over the past year regarding artificial intelligence and travel have focused on leisure travel, last week’s announcement by ChatGPT’s and Booking.com changed that dynamic. This latest ChatGPT/Booking.com partnership intends to help small and medium sized enterprises use AI to boost business (according to European reports, only 17% of European small businesses have adopted AI). Apparently, Booking.com hopes to capitalize on the effort by including corporate or managed travel in the list of AI-enabled functions. The program is available to business owners in 6 European countries – France, Germany, Italy, Poland, Ireland and the U.K. Just another attention grabbing headline with little to no likelihood of meaningful success? I think so.

Have a great week everyone. Go Seahawks.

Good Sunday afternoon from Manson, Washington . . . Our weekly Online Travel Update for the week ending Friday, January 30, 2026, is below. Accor garnered much of the travel industry’s attention this past week as it became the first lodging supplier to announce the launch of its own ChatGPT mobile app. Other headlines underscore several of the themes I expect to talk about this upcoming year – the growing influence of credit card travel platforms and AI-based or surveillance pricing. I hope you enjoy.

• • Accor Launches the “ALL Accor” App on ChatGPT. Today’s Update features two stories on the recent launch of the Accor AI application, including the Accor press release. Highlights (at least to me) from the recent launch include the following:
    
    • Accor manages to be the first major international lodging provider to launch a dedicated AI (ChatGPT) mobile application.
    • Users may access the app through the platform’s application store (prompts outside the application return content from multiple sources).
    • The app displays both pricing and basic property details before referring users to the Accor platform to complete the booking.
    • For now, referrals from the app to Accor’s platform are free (though Accor’s Chief Commercial, Digital and Tech Officer, Alix Boulnois, recognizes things might change).
    • Accor views the application as a direct channel and is providing its best rates to users of the channel, including loyalty program rates.
    • The app was first launched in the U.S. as a test market, but it is now available in countries where ChatGPT apps are supported.
  • Capital One Adds Discover Cardmembers to Travel Platform. In a move that is expected to grow its member base significantly (and further escalate the high-stakes competition among major credit card travel platforms), Capital One announced this past week that it plans to provide access to its travel platform (Chase One Travel) and other cardholder benefits to certain Discover cardholders. The phased integration will take several years to complete. Discover has approximately 60 million cardholders. This latest announcement comes on the heels of Capital One’s recently announced purchase of the payment management system, Brex, which will likely position the platform to be better able to pursue corporate or managed travel.
  • Travel Technology Association Sounds Alarm Over State Regulation of Surveillance/AI-Based Pricing. In late January, the Travel Technology Association (whose members include the major OTAs, GDSs and other booking platforms/intermediaries) issued a statement raising concerning over states’ ongoing efforts to regulate so-called surveillance pricing. While the effectiveness of these efforts remains somewhat unclear (see Trump Administration’s recently issued Executive Order purporting to limit state regulation of artificial intelligence), the concern appears real. According to the Association’s president, Laura Chadwick,

“[t]he consequences of these new state laws would increase operational costs, constrain revenue management strategies, and make it difficult, if not impossible, to align pricing with real-time market conditions automatically. Instead of helping the market work better, these bills would lock in inefficiencies and push companies toward blunt, one-size-fits-all pricing.”

Have a great week everyone.