Originally Posted by
Often1
DOT only regulates commercial air carriers (in this context).
True. So if it is a tour package, then it can be a SOL situation.
But if it is an air ticket only situation, then I beg to differ. Specifically, because OTAs do not issue the tickets per se (as they are issued by airlines), the issuing airlines ultimately is responsible. The job of OTA is to act on behalf of the airline, i.e. an agent. When IRROPS, airlines provide exception policies, these policies apply to OTA tickets as well. OTAs simply need to follow the airline's guidance to proceed.
DOT does not enforce its law over the OTAs (Yes - I agree that DOT lacks jurisdiction). Instead, DOT enforces its law over the airline who is ultimately for the ticket.