Duff on Hospitality Law

Good evening from the ALIS Conference in Los Angeles . . . Our travel-shortened Online Travel Update for the week ending January 23, 2026, is below. This week’s Update features a wide variety of stories, including updates on two stories we featured last week – Airbnb’s evolving hotel aspirations and investigations into Trip.com’s allegedly anti-competitive practices. I hope you enjoy.

• • To Allow AI Agents or Not to Allow AI Agents – That Is the Question. I’ve been a part of these discussions with several clients over the past few weeks. We definitely know Amazon’s perspective on this question, though as Perplexity has argued in recent court filings, Amazon appears to be engaged in the very same behavior that it is now seeking to stop by Perplexity. This week’s first story from PhocusWire provides a number of arguments in favor of allowing AI agents.
  • ChatGPT to Test Advertising. This past week, OpenAI announced that it would soon test sponsored ads in responses delivered to logged-in users of ChatGPT’s free and new Go tiers (users of ChatGPT’s higher subscription tiers will continue to enjoy ad free responses). No one should be surprised. At some point, these platforms, which require huge financial investments to sustain and grow, had to commercialize their platforms and extensive user bases. Significant questions remain about the newly announced advertising product (including, most importantly for hoteliers, how ads may be purchased, prioritized, etc.), but OpenAI did share some initial guiding principles about the product:
    
    • “Organic” AI responses will not be influenced by the advertisements
    • OpenAI will not sell users’ personal information to advertisers
    • Advertisements will only appear for logged-in users and will not appear alongside sensitive topics like personal health or politics

While travel was not specifically identified in the announcement, a sample screen shot included in the announcement featured a sample travel response and related advertising. For anyone still debating whether AI platforms (and related advertising) need to be addressed in your internal and external distribution discussions, this latest OpenAI announcement should be a call to action.

Have a great week everyone.