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Class Action Federal Lawsuit Aginst Delta RE: Best Fares Available

Old Sep 9, 14, 5:54 am
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Last edit by: mbwmbw
All files are available for download at: http://mbw.name/Files/FlyerTalk/Delta_Class_Action/

Furthermore, each document has been linked to the download location.

For a full download of the complaint and attachments click here.

Date Filed # Docket Text
08/07/2014 1 COMPLAINT with Jury Demand; against Delta Airlines, Inc. by Darla Opper. ( Filing Fee PAID $400 receipt number 0757-1939172) (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Civil Cover Sheet, # 9 Summons)(Shah, James)
08/07/2014 NOTICE Regarding assignment of this matter to Chief Judge William C Griesbach ;Consent/refusal forms for Magistrate Judge Duffin to be filed within 21 days;the consent/refusal form is available on our web site ;pursuant to Civil Local Rule 7.1 a disclosure statement is to be filed upon the first filing of any paper and should be filed now if not already filed (jcl)
08/07/2014 2 DISCLOSURE Statement by Darla Opper. (Shah, James)
08/08/2014 Summons Issued as to Delta Airlines, Inc. (mec)
08/20/2014 3 Refusal to Jurisdiction by US Magistrate Judge by Darla Opper. (Shah, James)
08/25/2014 4 SUMMONS Returned Executed by Darla Opper. Delta Airlines Inc served on 8/14/2014, answer due 9/4/2014. (Shah, James)
08/29/2014 5 Unopposed MOTION for Extension of Time by Delta Airlines Inc. (Smith, Renee)
08/29/2014 6 DISCLOSURE Statement by Delta Airlines Inc. (Smith, Renee)
09/02/2014 TEXT ONLY ORDER GRANTING 5 Unopposed MOTION for Extension of Time filed by Delta Airlines Inc., signed by Chief Judge William C Griesbach on 09/02/2014. The deadline for filing its responsive pleading is extended 14 days, until September 18, 2014. (cc: all counsel)(Griesbach, William)
09/18/2014 7 MOTION to Dismiss by Delta Airlines Inc. (Balassa, Gabor)
09/18/2014 8 BRIEF in Support filed by Delta Airlines Inc re 7 MOTION to Dismiss . (Attachments: # 1 Exhibit A - Best Fare Guarantee, # 2 Exhibit B - Best Fare Guarantee Claim Form, # 3 Exhibit C - Tabatabai v. West Coast Life Ins. Co, # 4 Exhibit D - Marine Travelift, Inc. v. Marine Lift Sys., Inc, # 5 Exhibit E - Tilstra v. Bou-Matic, LLC, # 6 Exhibit F - PNC Bank, N.A. v. Van Hoornaar, # 7 Exhibit G - NIIJII Entmt, LLC v. Troha) (Balassa, Gabor)
10/03/2014 9 Unopposed MOTION for Extension of Time by Darla Opper. (Shah, James)

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Class Action Federal Lawsuit Aginst Delta RE: Best Fares Available

Old Sep 8, 14, 10:09 pm
  #76  
 
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Originally Posted by DaDaDan
...2. They have a heretofore unknown computer, such as a quantum computer, that can actually calculate all possible solutions to this problem in a reasonable time....
Well, perhaps the colors on the award calendar are actually quarks leaking through?

Does anybody else have a good theory on what the colors actually mean?

And certainly it shows an element of uncertainty.
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Old Sep 9, 14, 12:49 am
  #77  
 
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Originally Posted by DaDaDan
. Anyone claiming a "true" best fare guarantee is claiming either:

1. They have an algorithm for solving non-polynomial problems in polynomial time (and thus are the winner of $1 million), or

2. They have a heretofore unknown computer, such as a quantum computer, that can actually calculate all possible solutions to this problem in a reasonable time.

Neither of these are likely.
But possible....Your Honor

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Old Sep 9, 14, 1:12 am
  #78  
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Originally Posted by mbwmbw
Correct.

I just want to keep you all informed with this.
Appreciate the updates mbwmbw ^
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Old Sep 9, 14, 2:30 am
  #79  
 
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Originally Posted by flyerCO
So basically what you're posting is that nothing has changed. DL hasn't responded except to say it needs time to respond. No real need to post this information, as nothing has changed.
Except it is an update. I now know what the filing status and dates are, and DL has responded and asked for more time. I didn't know those things before, or what the dates were. Now I don't have to google it because he did it for me.

Thanks for the update mbwmbw.
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Old Sep 9, 14, 5:55 am
  #80  
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Originally Posted by mbwmbw
Interesting read -- at least they understand married segments.

And likely why EF now cannot display any information read the post..

Article:
http://www.jsonline.com/watchdog/pi/...270819081.html (article also quoted below)
Alternative article link - try if the above doesn't work.

For the full lawsuit see: http://media.jrn.com/documents/deltaclassaction.pdf
A wiki with/for updates seemed good?
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Old Sep 9, 14, 6:27 am
  #81  
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Originally Posted by SCEflyer
The Plaintiff has requested a jury trial, and rejected the opportunity to have this matter adjudicated before a magistrate judge.
Odds that it will ever be heard by a jury are low -- most cases are settled. And even if it is, it still depends to a large extent on the judge's instructions to the jury.
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Old Sep 9, 14, 7:02 am
  #82  
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Originally Posted by DaDaDan
Separately, an actual best fare guarantee -- in the sense that a layperson might interpret it -- is actually impossible. Given any city pair, it is not possible to compute with certainty the lowest fare to get from A to B, assuming you permit connections. To do so, you would have to price every possible fare across every possible connection point, which would take more time than there has ever been in the universe. In computer science terms, this problem is NP-complete. Anyone claiming a "true" best fare guarantee is claiming either:

1. They have an algorithm for solving non-polynomial problems in polynomial time (and thus are the winner of $1 million), or

2. They have a heretofore unknown computer, such as a quantum computer, that can actually calculate all possible solutions to this problem in a reasonable time.

Neither of these are likely.
False. It's actually the "shortest-path problem" which is quite well known and easily solvable. It is nowhere near NP-complete.

And in the real world, it's even easier; once I've found a way to get from AAA to BBB for $222, any route that's already over $222 doesn't need to be extended, because it already lost.
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Old Sep 9, 14, 7:39 am
  #83  
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Originally Posted by sethb
False. It's actually the "shortest-path problem" which is quite well known and easily solvable. It is nowhere near NP-complete.

And in the real world, it's even easier; once I've found a way to get from AAA to BBB for $222, any route that's already over $222 doesn't need to be extended, because it already lost.
How long of a layover do you allow for? Remember, with broken fares the normal 4 hour domestic requirement does not apply. I've seen Orbitz price broken fares with overnight layovers to save a few bucks. Most other sites typically seem to limit layovers on broken fares to the nominal 4 hours used for through fares. How about connections between co-terminals? Orbitz prices broken fares where you arrive at ORD and then depart from MDW. Is that a reasonable search requirement? Then there's the issue of getting bucket inventory levels for all the possible flight options from the GDS'es. I don't believe that's a particularly quick operation. In short, I don't think it's quite as trivial as a search issue as you seem to believe. Also, as noted above, the connection options can get particularly obscure and long if you don't bound for connection time.
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Old Sep 9, 14, 10:37 am
  #84  
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It wouldn't be unreasonable to restrict connections to a small list of airports such as hubs or hubs and focus cities. They could also limit the number of segments per direction.
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Old Sep 9, 14, 1:07 pm
  #85  
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I can allow however long a layover I choose, including minimum and maximum (and by airport). The problem, in the real world, remains tractable.

If you want to assume the GDS will take 6 years to give you the data you need, then the problem will take at least 6 years to solve. But that doesn't mean the problem itself is hard.
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Old Sep 9, 14, 6:28 pm
  #86  
 
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Originally Posted by sethb
False. It's actually the "shortest-path problem" which is quite well known and easily solvable. It is nowhere near NP-complete.

And in the real world, it's even easier; once I've found a way to get from AAA to BBB for $222, any route that's already over $222 doesn't need to be extended, because it already lost.
Doesn't that last statement predicate that airfare cost is proportional to distance travelled....for which a counterexample or two may exist?
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Old Sep 9, 14, 7:02 pm
  #87  
 
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Originally Posted by LaserSailor
Doesn't that last statement predicate that airfare cost is proportional to distance travelled....for which a counterexample or two may exist?
No. The "shortest path" problem is with some pre-assigned value to any leg. It does not depend on distance, or any assumptions of an additive metric.

Seth is still technically wrong though. The said logic does work to search for fare breaks, but not solve the entire married fare problem.

Example. A-B-C or A-C (only routes). Shortest path algs would be able to easily search A-B(stop)B-C vs A-C. But the A-C fare itself could route via B with different metrics I would guess that a simple solution of the married fare problem would actually be quadratic in routes.

This is still a useless conversation. In practice the problem is trivial. If DL starts flying 1000000000 routes a day, then let's come back here.
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Old Sep 9, 14, 7:19 pm
  #88  
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Hi All,

I've updated the Wiki with each document and a link to view it. You can also browse the entire directory of information.
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Old Sep 9, 14, 7:36 pm
  #89  
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Interesting that they are asking for a $5,000,000 demand...
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Old Sep 9, 14, 7:39 pm
  #90  
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Originally Posted by exwannabe
No. The "shortest path" problem is with some pre-assigned value to any leg. It does not depend on distance, or any assumptions of an additive metric.

Seth is still technically wrong though. The said logic does work to search for fare breaks, but not solve the entire married fare problem.

Example. A-B-C or A-C (only routes). Shortest path algs would be able to easily search A-B(stop)B-C vs A-C. But the A-C fare itself could route via B with different metrics I would guess that a simple solution of the married fare problem would actually be quadratic in routes.

This is still a useless conversation. In practice the problem is trivial. If DL starts flying 1000000000 routes a day, then let's come back here.
I'm assuming input data is all published fares. So if the airline publishes a fare AAA-CCC (which routes through BBB), that's considered a single step for the algorithm. So there would be three fares to look at: AAA-BBB, BBB-CCC, and AAA-CCC. When finding the cheapest AAA-CCC involving two or fewer hops, it would look at all three (and also AAA-XXX and XXX-CCC, etc.)
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