In the Contract, AA repeatedly promised Mr. Bazerman that AA would transport his first and second checked bags for no extra charge. Specifically, the e-ticket confirmation email (memorializing the ticket purchase, as described further in paragraph 45) which AA sent to Mr. Bazerman expressly stated that Mr. Bazerman and his companion would each incur a fee of “USD0.00” for their respective first checked bags.

Additionally, both at the time of booking and at the time of travel, Mr. Bazerman had “Platinum” frequent flyer status with AA. The Domestic Terms promise Platinum members that AA will transport their first and second checked bags for no additional charge. The Domestic Terms also promise Platinum members that these checked benefits extend to companion passengers travelling on the same reservation. On information and belief, AA.COM presented substantially the same information to Mr. Bazerman before he purchased the ticket.

Mr. Bazerman also had oneworld Sapphire status because, both at the time of booking and at the time of travel, Mr. Bazerman held British Airways “Silver” status, which qualifies him for oneworld Sapphire status. Matching the promises AA makes as to members with Platinum status, the Domestic Terms promise oneworld Sapphire members that AA will transport their first and second checked bags for no additional charge. On information and belief, AA.COM also presented substantially the same information to Mr. Bazerman before he purchased the ticket. As with Mr. Bazerman’s Platinum status, AA knew that Mr. Bazerman had oneworld Sapphire status. Mr. Bazerman specifically demonstrated his qualification for oneworld Sapphire status to AA both by telephone and again in person when he checked in at the airport in Phoenix.

"1. This case is about American Airlines, Inc.’s (“AA”) systematic failure to honor the contracts it enters into with its passengers. AA’s passenger contracts include promises that specified passengers are permitted to check a first, second, and/or third bag for no additional charge. These passengers include “elite” members of certain frequent flyer programs and those who purchase certain types of tickets, such as business class or first class. AA contracts also routinely promise certain other passengers that they are permitted to check their first bag for no additional charge. Yet, AA systematically required these passengers to pay to check bags that AA had promised to transport at no additional charge, and thus breached its contract with affected passengers."