Originally Posted by
Sabasi
CX is not so "foreign" as it conducts lots of business within the US with US residents. The mere fact that the flight in question is outside the US does not necessarily preclude US-DOT jurisdiction, by consent as part of CX's operating authorization within the US or by regulation, federal law, or international agreement.
While you are correct that US DOT has some jurisdiction over foreign airlines, it's consumer protection rules do not apply to wholly foreign flights that weren't sold by that airline in the US. (More importantly, the rules simply dont require an airline to create award availability in response to a schedule change 6 months in advance.)