The problem is that they can't be held accountable for something that's not a law or regulation, so they needed to get them on something.

CO published the 3-hour rule in their customer commitment, and they grossly violated that. Hence the deception.

This is a huge win for consumers because for once, the government is actually cracking down on a service provider for misbehaving. I think this is a good thing.

The big learning experience for CO is that they are responsible for their express operators. Remember CO's initial response was to defer to XJ. That's not gonna fly anymore. $50K fine + 50 refunds + 50 ETCs + whatever pending litigation is forthcoming, yeah, I think they got the message now.

As for the affected consumers, this is not an easy redress type item. It's not like the airline overcharged them X dollars, so you can give them $X back + something. They deliberately are not doing anyting for affected passengers, so they can sue or do whatever they want. They're free to take up a class action or whatever.