26. This fare class and tariff data is published by Delta to airline agents and users of any Global Distribution System (“GDS”). Certain publicly available websites make GDS data available for a fee, including expertflyer.com.

42. Websites such as expertflyer.com and flightstats.com allow specialized users to review fare class availability for given flights in real time

43. In November, 2012, Plaintiff’s counsel compared, in real time, prices and fare classes made available to consumers on delta.com, with Delta’s true inventory—as revealed by Delta’s own voluntary GDS reporting, and as displayed on expertflyer.com.

47. Real-time availability on expertflyer.com revealed that for Flight DL 1889, from MSY to SLC, available seats existed in fare class “T”—the second to lowest fare class at the time. See Exhibit B. Real-time availability on expertflyer.com and on delta.com also revealed that for Flight DL 2157, from SLC to SEA, available seats existed in fare class “T”—again, the second to lowest fare class. See Exhibit C.

71. Specifically, counsel conducted seat inventory searches using expertflyer.com on four different dates, at different times of the day, and for travel on 12 different future dates, all consistent with the parameters discussed above, which mimicked Plaintiff’s original search on delta.com.