Originally Posted by
channa
Did you even read the press release?
It says that UA printed the old limit on its ticket jackets after the new limits were in effect.
In January 2011, the Department’s Aviation Enforcement Office learned that United had given a number of passengers ticket wallets printed after the increase took effect that continued to list the old figure of 1,000 SDRs as the limit on baggage liability.
So the fine is not for using old ticket stock (that would probably be nitpicky). Rather the fine is for not updating the language as it was supposed to and continuing to print the old limits, despite new limits being in effect.
Remember that at the time, UA's priorities were painting planes, updating safety videos and coming up with clever marketing such as, "You're going to like where we land." As such, regulatory compliance on issues like this probably took a back seat.
Umm, I did read it. I work in regulatory compliance. The facts are normally not the same as what's published, as it is an arcane world of "implementation", especially when discussing labels regulated by federal law. That order for new ticket stock was in all likelihood made well in advance of the rules change.