But does pre-emption apply to frequent flyer programs, which are arguably not "a price, route, or service" of an airline? I would think that such an argument offers a way around pre-emption. I would note that Galbut v. American Airlines, Inc., E.D.N.Y.1997, 27 F.Supp.2d 146, would suggest that at least upgrades pursuant to a frequent flyer program are pre-empted, but then again, that's only a mere trial court ruling that's not binding on any other court.

I don't think that any case law completely forecloses any claims based on contract, fraud, deceptive trade practices, or illegal lotteries.

I just ask that whoever brings the class action gets us more than a few stinking coupons.