Duff on Hospitality Law

Happy Monday evening from Seattle . . . Our weekly Online Travel Update for the week ending Friday, December 19, 2025, is below. This week’s Update features a heavy concentration of important legal updates on local Chinese efforts to investigate the practices of OTAs, the FTC’s newly announced investigation into Instacart and its alleged surveillance pricing practices and an important German court decision that may have wide ranging effects across Europe on pending class actions against Booking.com. Enjoy.

• • ChatGPT’s App Store Is Open for Business – Everyone’s Business. OpenAI announced this past week that it is now allowing third party developers to build and list apps inside ChatGPT. Once approved, the apps will be listed in ChatGPT’s App Directory. Users can summon these news apps via the ChatGPT tools menu, via @mentions or when ChatGPT deems the app relevant to the current session. In theory, a single vacation planning session could trigger multiple travel apps – competing OTAs, suppliers, etc. So much for ChatGPT’s initial pilot partners – Expedia and Booking.com – and let the battle for session relevance among competing apps on ChatGPT begin.
  • FTC Launches Investigation into Instacart Pricing Practices. It was just two weeks ago that we committed to exploring further the practice of personalized (or “surveillance”) pricing, its use in online transactions (specifically travel) and likely regulation. With the addition of personalized pricing to our daily news searches, my inbox is already being inundated with personalized pricing stories and newly announced regulations. Instacart has featured prominently these past two weeks as a study two weeks ago claimed to demonstrate the wide variety in pricing among users for the same items and then this week, likely in reaction to the announced study, the FTC has reportedly sent Instacart a civil investigation demand to investigate the online retailer’s pricing practices.
  • German Court Allows Hoteliers’ Claims Against Booking.com To Proceed. In a ruling last week, a Berlin court found that Booking.com’s use of rate parity provisions between January 2013 and January 2016 restricted German hotels’ ability to set competitive prices in violation of EC competition laws. According to the court’s decision, the OTA’s use of both broad parity provisions and later, narrow party provisions, unlawfully constrained hotels’ pricing freedom. The ruling clears the way for nearly 1,100 German hotels to proceed with competition claims against the OTA. The Berlin court’s decision follows an earlier 2024 decision by the European Court of Justice that found that Booking.com’s use of rate parity provisions violated competition law across Europe. This latest decision could prove quite helpful to other EU hoteliers and their pending class action claims against Booking.com arising, in part, out of its use of the same rate parity provisions.

Have a great week everyone, and Happy Holidays.

Good Sunday afternoon from Seattle . . . Our weekly Online Travel Update for the week ending Friday, December 12, 2025, is below. This week’s Update includes a number of updates to stories we featured previously, including stories on the existential threat (or not) to OTAs posed by new AI platforms and the Trump administration’s threatened takeover of state-level AI regulation (no longer a threat, but a reality). Enjoy.

• • Do AI Platforms Really Pose an Existential Threat to OTAs? This week we offer several conflicting perspectives on the question from Booking Holdings’ CFO (who believes, among other things, that AI will expand the overall market of online travel benefiting Booking Holdings and other online intermediaries (“rising tides”)) and Skift’s Dennis Schaal (who, I believe has a far more realistic and less vested perspective, believes that change for the OTAs is unavoidable).
  • Google Ties AI Overviews with AI Mode. For those of you who have seen my presentation on AI and distribution, you’ll understand the significance with which I viewed this latest announcement from Google. Mobile users of Google’s AI Overviews (which is just about everyone) will now be able to seamlessly transition from AI Overviews to AI Mode for further detail or clarification on their initial query. Users of AI Overviews will be able to “Ask a follow up,” which will take them directly into AI Mode. Together, this latest announcement and Google’s previously announced plans to position its AI mode as a complete travel planning and booking platform will only further threaten the relevancy of traditional online search.
  • Amazon vs. Perplexity. In early November, Amazon filed suit against Perplexity in Northern California District Court alleging that the AI platform’s use of AI agents (Comet AI Agents) on Amazon’s website not only violates Amazon’s terms and conditions but also constitutes violations of federal (Computer Fraud and Abuse Act) and California state (California Comprehensive Computer Data Access and Fraud Act) law. Amazon seeks both special (injunction) and monetary (damages) relief. How might such a lawsuit (or its outcome) affect online travel? Great question. We see many potential parallels to be drawn and potential lessons to be learned. For anyone concerned about how AI agents might access and use their websites, I’d encourage you to read the complaint and specifically, those sections detailing Amazon’s efforts to restrict AI agents’ access. Expect to see updates on Amazon’s claim in future Online Travel Updates. A copy of Amazon’s complaint is linked below.
  • OpenAI Curtails App Suggestions – For Now. By now, most everyone is probably familiar with the recent launch of apps (including Expedia and Booking.com) within ChatGPT’s ecosystem. Not only can users “summon” these apps through various means, but the apps can also be offered up by ChatGPT whenever ChatGPT believes that the app may be relevant to the user’s prompts. Apparently, these app suggests look strikingly similar to advertisements and as a result have created quite a backlash among ChapGPT users (who naively believe that ChatGPT will remain forever ad free). For now, OpenAI is turning off the app suggestions and may even allow users to permanently turn off app suggestions (or at least tailor which apps are suggested) in the future.

We have a lot in store for 2026, including the introduction of a new Online Trave Update podcast.

Have a great week everyone.

Good Sunday evening from Seattle . . . Our weekly Online Travel Update for the week ending Friday, December 5, 2025, is below. With last week’s Thanksgiving holiday break, our list of stories this week is longer than usual. Enjoy.

• • Otto Introduces AI Assistant for Business Travel. Seattle-based Otto’s release this past week of its new AI-enabled business travel assistant, Otto the Agent, garnered many of the industry’s headlines, including headlines by Seattle’s own Geekwire. If you are a regular reader of our Updates, you know that Geekwire is Seattle’s Pacific Northwest Focused technology news service. Those behind the new startup include a who’s who of travel industry veterans, including Spotnana’s Steve Singh, Orbitz’s Barney Harford and Expedia’s Michael Gulmann. The platform, which has been in beta tests since August 2024, is designed to learn travelers’ travel habits and then apply those learnings to planning and booking (without leaving the platform) travel – for now, flights and hotels. For the next 12 months, the platform will be free to individual users and small businesses. 

• • Personalized Pricing in Legislative and Regulatory Crosshairs. Given the number of questions we’ve fielded over the past few weeks regarding personalized pricing and now New York’s recently enacted legislation, I think it time to put personalized pricing on our distribution radar and list of “distribution” related topics that we monitor daily. This week, we feature two stories on the growing calls to regulate so-called “surveillance” pricing, including New York’s October passage of surveillance legislation that requires New York businesses to notify consumers whenever personal information is used when setting pricing. New York is not alone is considering steps to combat this allegedly abusive practice as several states considered similar (often bipartisan) legislation this past year. Much of this legislation activity is built on earlier efforts by the FTC that were abandoned with the change in administrations. How these state-level efforts might fair in light of the Trump Administration’s threatened Executive Order limiting state-level regulation of artificial intelligence remains to be seen. How these rules might affect the travel industry, including the use of personalized offers and promotions (think targeted loyalty program promotions) also remains to be seen. We plan to cover all of these topics and more in future Updates.

• • Confusing Headline Calls into Question Hopper’s Long Term Travel Plans. On November 24, Skift ran a story stating that Capital One (one of the largest known users of Hopper’s B2B booking platform and Hopper investor) was “buying” (not licensing, as it already likely does) Hopper’s software that powers Capital One’s cardholder travel platform and hiring several members of Hopper’s hotel and engineering teams.  What this change might mean for Hopper’s declining B2C and remaining B2B distribution business is unclear. 

• • Power of Event Based Travel Leads Trip.com to Add Tickets to Its Online Inventory. Trip.com recently announced a new partnership with Ireland-based ticketing company, Coras, that will provide the traditional OTA and its users with access to tickets for major concerts, sports and theater events. Users of Trip.com will now be able to see real time availability and pricing for events “in path” without being re-directed to another booking website. According to Coras CEO, Mark McLaughlin, events (thank Taylor Swift and her recent Eras tour) have become a huge motivator for travel and event tickets are often the first product that a user purchases. Combining event tickets with other travel products provides travel suppliers an opportunity to upsell flights, hotels and transfers (and not vice versa). From what we’ve learned recently, event ticket sales and distribution can be very different than the distribution of traditional travel products.

• • ARC Shuts Down Program Selling Traveler Data to Department of Homeland Security. This hopefully brings an end to the controversial practice by the Airlines Reporting Corporation (ARC) that several of you brought to my attention over the past few weeks.    

Have a great week.

Good Saturday afternoon from Seattle . . . Our weekly Online Travel Update for the week ending Friday, November 21, 2025, is below. Google captured much of the industry’s attention and imagination early in the week with its announcement of new AI-enabled travel booking tools, but it then spent much of the remainder of the week walking back its travel industry intentions. Never a dull moment. Enjoy.

• • Trump Administration to Challenge State Regulation of AI. For those of you who have seen my presentation on AI and its effects on the travel industry, you will likely recall the uncertainty that I expressed about future regulation of AI, particularly at the state level. While there are numerous examples of states legislating in this area (Colorado being the example that I tend to discuss most in my presentations), the future of those efforts is in jeopardy. Having failed to include language prohibiting state regulation of AI generally in its “Big Beautiful Bill,” the Trump administration is now considering an executive order directing the Department of Justice to create an “AI Litigation Task Force” to sue states for adopting AI legislation or regulation that allegedly violates federal law, including Constitutional protections around free speech and interstate commerce. The order also directs the Department of Commerce to explore options for withholding federal funds from states that legislate in the AI arena and tasks advisors to the administration to draft federal legislation establishing a federal regulatory framework for AI. President Trump is expected to sign the executive order as early as this next week. Bottom line, don’t expect to see meaningful US regulation or oversight of AI any time soon.
  • Travelers Increasingly Look to OTAs to Start Their Hotel Searches. In a report released this past week, Siteminder shared the results of its recent study of global travelers (12,000 travelers across 14 countries) and their booking and travel preferences. A complete copy of the report is available in the story below. A couple of key takeaways . . .
    • Travelers are now more likely to begin their search for hotels on OTAs (26%) versus search engines (21%)
    • Of those travelers who begin their search with OTAs, an increasing number (18%) elect to book direct (3.3% increase over last year)
    • Those using AI as a first step in their exploration has increased fourfold from 1% to 4% (and even higher among younger demographics), though those wanting AI-powered capabilities as part of their search (including price monitoring) has increased significantly (now 80%).
  • Consumer Class Action to Move Forward Against Booking.com. Separate and apart from the pending class action by European hoteliers against Booking.com, the Consumer Competition Claims Foundation (“CCC”) and Consumentenbond announced plans this past week to move forward after failed settlement discussions and to take their claims to a Dutch court. The claimants are demanding that Booking.com stop its alleged abusive and misleading practices and compensate Dutch consumers for damages suffered. The potential class includes all Dutch consumers who booked hotel rooms online through Booking.com or other online platforms. As of the date of last week’s announcement, 267,000 people had registered to be part of the class.
  • Google Launching AI Mode Flight and Hotel Booking Tools. In today’s Update, we offer several stories (including Google’s own press release) detailing Google’s announcement this past week of several new travel related tools, including, most notably, the upcoming release of new Google AI mode agentic booking tools that allow users to book reservations for flights and hotels. The announcement comes on the heels of Google’s recently announced agentic booking tools for booking restaurant reservations, buying event tickets and making beauty and wellness appointments. While Google is still developing the new tools (an official launch date was not provided), it did provide some details about the new tools and the anticipated user experience (which from this person’s viewpoint, sounds a lot like a natural language facilitated metasearch platform) . . .
    • Google is working with industry partners Booking.com, Expedia, Marriott, Choice, IHG and Wyndham in developing the new tools. Google expects to announce additional industry partners (“of every size” including aggregators) at the time of the launch.
    • Users will be able to select among identified travel partners based on price and other attributes.
    • Booking flows, payments, etc. still need to be worked out, though Google made clear that industry partners will serve as the merchant of record and will manage / service existing bookings.
    • Google wants to incorporate users’ previous interactions with AI Mode into the booking tools and user experience (e.g., preference for luxury travel, member of particular loyalty programs, etc.).

Following the announcement, both industry pundits and investors raised questions about the effects of the new Google tools on existing OTAs, which leads us to our final featured story below.

• • Google Walks Back Industry Intentions Following Latest Product Announcement. Facing questions about its long term industry intentions and possible OTA (also known as ADVERTISERS) disintermediation (and loss of market value) following its announcement of forthcoming agentic flight and hotel booking agents, Google was quick to clarify (walk back) its intentions. In a follow up interview with Skift, Google’s vice president of engineering for Travel and Local, Julie Farago, tried to clarify Google’s intentions – “Google has no intention of becoming an online travel agent.” According to Farago, even with the introduction of the new AI tools, users will continue to work with their partner of choice (whether OTA or direct channel) as they do now with standard search.

All of this leads the skeptic in me to question whether AI will really be the game changer that it is often promoted to be. Yes, it may present a far more useful and powerful form of search allowing users to access and organize content in ways never before seen, but will the dominant (and likely, most trusted) AI players really do or try anything that disrupts the current status (and financial benefits) of online search and booking? We know that the OTAs are working hard to ensure that outcome. Regardless, the next months and years will definitely be interesting. I love this job.

For those of you celebrating Thanksgiving, I hope you and your families have a wonderful holiday. Our next Online Travel Update will be on Friday, December 5. Have a great two weeks.

Good Sunday morning from Seattle . . . Our weekly Online Travel Update for the week ending Friday, November 14, 2025, is below. This week’s Update features of variety of stories, including Apple’s recent Digital ID announcement. As promised last week, we’ve also included a copy of the transcript from last week’s Expedia earnings call. Finally, for our readers under the age of 18, you may want to consult with your parents before proceeding. Enjoy (but not too much).

• • Apple Announces New Digital ID Functionality. On Wednesday, Apple announced Digital ID, a new feature that allows iPhone users the opportunity to use digitally stored passport information to pass through TSA checkpoints without a physical passport of identification. Today, the functionality is limited to U.S. domestic travel (12 states and 250 airports (with more on the way)) and cannot yet be used for international border crossings. With important digital ID changes coming to the EU in the next few years, expect to see more about digital IDs in upcoming Updates.
  • Airbnb Sues Over Alleged Conspiracy Against Short Term Rentals. This past week, Airbnb sued the City of Biloxi, Mississippi, in federal court alleging that the City illegally conspired with the Mississippi Hotel & Lodging Association to severely limit short term rentals and thereby raise the Association’s members’ (local hoteliers) profits in violation of state and federal anti-trust law. According to Airbnb’s complaint, the Association, through its illegal conspiracy with the City, has prohibited short term rentals in large sections of the City, severely restricted short term rentals in others and inserted itself in unprecedented ways into the review and approval of new short term rentals applications. For those of you interested, a copy of the complaint is linked in the story below.
  • Airbnb Launches Hotel Pilot. Airbnb is moving ahead with its previously announced plans to re-enter the hotel industry. Airbnb has launched a pilot program in three cities – New York, Los Angeles and Madrid – where restrictive short term rental regulations have severely limited inventory. For now, the pilot is focused on independent and boutique hotels. Recent changes to the Airbnb platform now allow users to view room types and other detailed property information (unlike Airbnb’s first foray into hotels) like more traditional hotel booking platforms. According to Airbnb CEO, Brian Chesky, the addition of hotels presents a multi-billion dollar opportunity that won’t be dilutive to its existing short term rental business. Chesky further believes that Airbnb won’t need to invest the billions of dollars in marketing that its competitors (Expedia and Booking.com) do because of its existing strong brand identity (and resulting direct traffic). Stay tuned.
  • Want to Get Lucky? Plan a Vacation. Every now and then we encounter a story that creates far more questions than it answers. Last week was one of those moments when we came across a press release on the Booking.com website claiming that for the majority of American women (56%), a partner planning and booking a trip is just as arousing, if not more, than foreplay. What? Let the questions begin. I cannot wait to raise this nugget in my next Booking.com negotiation.

Have a great week everyone. I’m booking a trip on Booking.com. 

Good Sunday morning from Seattle . . . Our weekly Online Travel Update for the week ending Friday, November 7, 2025, is below. Expedia’s quarterly earnings report garnered most of the attention this week as Expedia reported relatively strong third quarter results. We’ll include a transcript from this week’s earning release call in next week’s Update. Enjoy.

• • Expedia Posts Better Than Expected Quarterly Earnings. Expedia’s third quarter earnings reflected continued strength in its B2B business and a stabilizing B2C business. Here are a few of the key numbers:
    • Company-wide revenue grew 9% YOY to $4.4 billion (B2B revenue grew 18% YOY)
    • Advertising revenue grew 16% YOY
    • Company-wide gross bookings grew 12% YOY (B2B bookings grew 26% and B2C bookings grew by 7%)
    • Booked room nights grew by 11% (outpacing competitors Airbnb and Booking.com for the quarter)

When asked during the earnings call about Expedia’s current AI efforts, CEO Ariane Goren noted that the Company had two primary priorities – ensuring that its brands and content appeared in responses to users’ prompts on the major AI platforms and directing traffic from those platforms back to Expedia. Goren’s comments regarding the leads received by Expedia from popular AI platforms mirrored those of Booking Holdings’ Glenn Fogel just a week earlier - few leads today but growing and good quality.

• • AI, AI Agents and Corporate Travel. For the past few months now, the industry (us too) has focused almost exclusively on AI and AI agents and their effect on leisure travel. What about managed and corporate travel? What complexities do travel policy compliance, expense management and duty of care obligations introduce? According to recent comments from some of the largest corporate travel players, these added complications will make it impossible to replace TMCs and expense platforms entirely. Sounds like self-preservation talk to me. From my perspective, as AI tools are perfected in leisure travel, their extension into corporate and managed travel (and their complex data sets, which seem like natural fits for AI) seems inevitable. Anyone agree?
  • What Lessons Can Be Learned from Airlines and ChatGPT? According to recent research conducted by PROS, an airline retailing and revenue management company, referrals from leading AI platforms to airline websites is growing quickly. In September of this year, ChatGPT accounted for 2.3% of all referral traffic from search engines to airline websites (this number is up from 1.8% in August). While the importance of AI platforms may be increasingly generally, airlines may have a hard time benefitting from the increased usage. According to PROS, a wide margin of the traffic generated through ChatGPT today goes to OTAs and metasearch sites and not airlines themselves. Note that these results are quite different than the results of the AI behavioral study by Propellic that we featured in an earlier post, but they may be indicative of where hotel search is going in the future.

Have a great week everyone. 

Good Sunday morning from Seattle . . . Our weekly Online Travel Update for the week ending Friday, October 31, 2025, is below. Booking Holdings garnered most of the attention this past week as it reported its third quarter earnings and updated investors on its ongoing artificial intelligence efforts. A copy of the earnings release call transcript is linked below. Enjoy.

• • Updates on Booking.com’s Payments Business. With so much attention being paid these days to Booking.com’s AI announcements, we’ve all lost track of Booking.com’s ongoing efforts to stand up a successful payments’ platform. Anyone remember “Facilitated Payments?” Payments remain a critical component of Booking.com’s overall connected trip strategy and is likely one area (at least according to Booking.com) where AI platforms won’t be racing to displace existing players or structures.
  • Is Organic Search Dead? According to Kayak’s CEO, Steve Hafner, organic search is at least dying. In a recent Skift interview, Haftner shared that large language models (LLMs), including Google’s AI Overviews, are to blame for rising customer acquisition costs. With Google’s placement of entirely self-contained AI driven responses at the top of users’ search results, organic search is becoming less relevant and forcing advertisers like Kayak to invest more in paid search. According to Haftner, anyone who has previously relied on organic links is likely to suffer the same consequences. The result? At least for Kayak, the changes resulted in a recent $457 million accounting write down on its brand. With these important changes in search being brought about by AI (and in particular, Google’s AI Overviews and AI Mode), one must ask how relevant are Google’s newly proposed search boxes (see story below) other than to satisfy EU regulators?
  • Booking Holdings Updates Investors on AI Efforts (and Reports Quarterly Earnings). Booking Holdings released its third quarter earnings report this past week and while Booking reported a relatively strong third quarter (including some first time comments on its growing B2B business), most of the industry’s attention was focused on CEO Glenn Fogel’s comments on AI. A few takeaways . . .
    
    • It remains far too early to say with any certainty that AI is the travel industry disrupter that everyone claims it is. Yes, Booking.com is enjoying great PR (“first wave”) with regard to its new ChatGPT app, but what that app actually means for new customer acquisitions or direct channel growth remains unknown.
    • Bookings generated through AI enabled platforms reflect higher user engagement – better conversion, fewer cancellations and high customer satisfaction. All good things.
    • Booking believes that irrespective of where travelers may actually begin their search, platforms like Booking.com will continue to serve a critical (irreplaceable?) role in fulfilling and servicing the bookings (and the many complex relationships that are required to create and pay for those bookings) that ultimately result from those searches.
    • My two cents . . . Despite Glenn Fogel’s seemingly dismissal of the threat posed by AI platforms, I believe Booking.com is as afraid of AI and its possible disintermediation of travel intermediaries like Booking.com as it is excited about the potential opportunities presented by AI. I also believe that the outcome here will depend more on the aspirations (and existing or future business models) of the AI platforms versus anything that Booking or other intermediaries might ever do. Walking away from billions of dollars of ad revenue (or possible revenue) generated through the intermediaries will be difficult for any platform player. Google never made that kind of leap with traditional search. Will Google (or other newcomer AI platforms) behave differently with AI?
  • TripAdvisor to Soon Launch Its Own ChatGPT App. How relevant will this app actually be? See discussion above.

Have a great week everyone.

Good Monday morning from Seattle . . . Our Online Travel Update for the week ending Friday, October 24, 2025, is below. This week’s Update introduces readers to ChatGPT’s new browser, ChatGPT Atlas (and its new Agent Mode), and offers varying views on ChatGPT’s (and similar AI powered platforms’) long term effect on travel, the future role, if any, for today’s travel intermediaries and when/how the industry should respond. I hope you enjoy.

• • Should Suppliers Race to Make Inventory Available on ChatGPT? That’s the million dollar question. Faced with successive announcements from OpenAI over the past few weeks, including, the recent introduction of new ChatGPT travel apps from Expedia and Booking.com, hoteliers, short term rental companies and other travel suppliers face a dilemma. Do they push ahead now to do anything possible to ensure their inventory is available in some form on these new platforms or do they wait? Does waiting give early adopters (OTAs) even more of an insurmountable advantage? For some, like Airbnb’s Brian Chesky, the answer appears to be to wait (at least for now). Others are convinced that suppliers must move now, and companies like Direct Booker seek to provide suppliers the tools to do so.
  • Can ChatGPT and Others Like It Reduce the Travel Industry’s Dependence on Today’s Powerful Intermediaries? Or will these platforms only serve to cement intermediaries’ already outsized control and influence? (I’m full of questions this week.) Answers to these important questions also vary, but I tend to believe (as does Brian Chesky and the author of one of our stories below) that OTAs are too large (and too smart) to be displaced by these new AI platforms and if anyone is well positioned to leverage the platforms to their benefit, the OTAs are. Search has not displaced the OTAs (and in fact, the largest search engines and OTAs have a well-documented symbiotic relationship), so why should these new tools, particularly as they become more commercialized.
  • Introducing ChatGPT Atlas. On the heels of ChatGPT’s announcement of its new app store, ChatGPT introduced this past week a new web browser, ChatGPT Atlas, that allows users to use natural language searches to browse the internet. Users can also use the browser to complete certain tasks on the user’s behalf through the browser’s new feature, Agent Mode. Of course, OpenAI’s video demonstration of the new product featured (once again) a travel application as ChatGPT’s lead software designer for the project demonstrated the new agent tool being used to complete bookings on Air France. The introductory demonstration and other travel examples (one using Expedia’s VRBO platform) are available in the stories below. Atlas is now available in preview for ChatGPT Plus, Pro and Business users.

Have a great week everyone.

Good Saturday morning from Seattle . . . Our weekly Online Travel Update for the week ending Friday, October 17, 2025, is below. Compared to last week and its seemingly endless parade of announcements around AI and online travel, this week’s unexpected shortage of announcements provided many of us the opportunity to catch our breath and to consider further the many changes over the past few weeks. I hope you enjoy.

• • Kayak Debuts Natural Language Searches.  This past week, Kayak officially debuted its latest AI offering, AI Mode.  AI Mode allows users of the metasearch site to use natural language prompts to plan and search a variety of travel products and services.  The new functionality is powered by ChatGPT and leverages the data of Kayak’s many travel providers.  This new offering is in addition to Kayak’s separate Kayak.ai site, which remains a platform for continued AI experimentation and testing by Kayak.

• • Google Proposes New Changes to Search Results (Again) to Satisfy EU Regulators.  According to a recent report from Reuters, Google is again proposing changes to its display of search results in its ongoing effort to satisfy its obligations under the DMA.  This newest proposal reportedly provides OTAs and similar “vertical search services” the opportunity to bid on and display search results box alongside Google’s own search box.  Boxes will feature Google’s and the winning OTA’s available inventory.  Suppliers will have the opportunity to display their own box, the location of which, according to the Reuters report, will be above or below the vertical search services box “depending on the relevance to the user’s query.”

Have a great week everyone.

Good Sunday morning from Seattle (actually, about 180 miles south of Seattle at one of Marriott’s new Post Card Cabins in Glennwood, Washington) . . . Our weekly Online Travel Update for the week ending Friday, October 10, 2025, is below. This week’s OTU includes recent product updates from both Expedia Group (Hotels.com) and Booking Holdings (Booking.com) as well as several perspectives on the major “app” announcement that came out of last week’s OpenAI Development Conference. Enjoy.

• • Hotels.com Introduces New “Immediate” Loyalty Program Feature. Expedia Group’s Hotels.com has introduced a new loyalty feature (Save Your Way) that allows members of Expedia Group’s loyalty program, One Key, to use loyalty program discounts immediately when booking on Hotels.com or redeem them later for a booking on Hotels.com, Expedia or VRBO. Hotels.com claims that the feature is a first of its kind. According to Expedia, early results suggest that the new feature is proving most popular among business travelers who elect to use the discount immediately. Here’s my immediate reaction . . . This is simply rate discounting, and for many suppliers, unauthorized rate discounting. Bigger picture, will this new discount appear on search and meta search site results? If yes, how do suppliers handle the resulting parity fall out? Finally, how are competing intermediaries likely to react to this new feature? Time to check those contracts everyone.

• • Both Expedia and Booking.com Introduce New AI Powered Features. Both Expedia and Booking.com introduced last week a suite of new AI features for both travelers and the platforms’ supplier partners. Among its many announced new features, Booking.com has introduced Smart Messenger and Auto Reply to “improve” communications between suppliers and their guests.  Expedia has announced Lodging Sponsored Listings API, a new advertising tool for Expedia’s B2B partners.   

• • OpenAI Partners with Expedia and Booking.com to Launch ChatGPT Apps. The big announcement in online travel last week came out of OpenAI’s annual development conference on Monday. ChatGPT has become an app “platform” open to third party developers. As part of the announcement, Expedia and Booking.com both announced new ChatGPT apps (with a TripAdvisor app soon to follow) that allow users of the AI platform to browse, select and ultimately book accommodations on the ChatGPT platform. (As we have noted in prior Updates, the inability to actually book travel without leaving a chosen AI platform has been noted in several studies as a source of frustration for AI users generally) To access the OTAs’ content, users must first type in the name of the app (e.g., “Expedia” or “Booking.com”) into their prompt or, and this where things get really interesting, the platform will suggest an app that the platform believes is most responsive to users’ prompt if no app is specified. Connectivity between ChatGPT and the OTAs is provided via Model Context Protocol (MCP). The offerings are currently available to ChatGPT users (Free, Go, Plus and Pro plans) outside the EU. Industry reactions to the announcement have been mixed – from wild hysteria to shoulder shrugs. From my perspective, the need to summon the app in advance is definitely a drawback (and likely means that the announcement is not the game changer that many initially thought it might be). The scary factor here is the fact that ChatGPT will choose between the competing apps in the absence of a specific summons. How does ChatGPT choose between the competing apps? Will ChatGPT eventually monetize this choice (e.g., whomever pays ChatGPT the most)? Are the two (soon to be three) apps the only sources of content to respond to users’ prompts? Our friends at Seattle’s own Geekwire offer an interesting perspective on the announcement and the potentially perilous position that Expedia now finds itself.

• • Perplexity Launches Comet with Expedia. Also last week, AI platform Perplexity (as I’ve noted, one of the most interesting AI platforms for the travel industry) announced the launch of a new AI browser and AI assistant, Comet. Expedia Group joined the launch as one of the browser’s initial launch partners and is offering a first-of-its-kind incentive (Silver status on Expedia’s One Key loyalty program) to travelers to download the new browser. Users of the new browser and assistant will also be able to search, select and book travel without leaving the Perplexity platform (which is consistent with Perplexity’s earlier announced partnerships with TripAdvisor and Selfbook).

• • Questioning Airbnb’s Sincere Interest in Hotels? Recently posted job openings suggest that you might want to think otherwise. For those of you have been part of my recent AI and distribution presentations, Airbnb is one of the platforms I’m watching most closely in the months ahead. 

Have a great week everyone.