WYSTC 2016, Belgrade Serbia - WYSE TRAVEL CONFEDERATION - STAY WYSE

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WYSE TRAVEL CONFEDERATION

           Distribution Roundtable
                   Briefing
                       WYSTC 2016, Belgrade ‐ Serbia

                                                     9/22/2016

The purpose of the briefing paper is to allow all roundtable participants to gain a common understanding of current
issues areas and the status quo with regards to the relationship between OTAs and youth travel accommodation
providers. It serves not as a comprehensive report, but as a working document of the state of play in the area of
accommodation distribution practices which will allow the participants to have an informed and structured discussion
during WYTSC.
Background information

Against the backdrop of increasing consolidation of major Online Travel Agencies (OTAs) and recent policy
changes with regards to rate parity clauses, during this meeting the current relationship between OTAs and
accommodation providers will be discussed. The goal of the meeting is to identify the current issues related
to distribution channels in the youth travel accommodation industry and to have an open discussion on the
findings of the OTA survey and the current Sydney Declaration.

Structure

The briefing paper consists of a short overview of the various types of platforms, facts and figures, and the
current trends that are shaping the industry (chapters 1 + 2). Chapter 3 summarizes the main issue areas
accommodation providers experience in their business relationships with online platforms. Chapter 4
reflects the current governance structure in various regions of the world with Europe as the main case study.
In a more comprehensive report following the distribution survey post‐WYSTC, we plan to cover other world
regions in greater detail. Chapter 5 contains the current Sydney Declaration. In chapter 6 the results of the
survey which accompanied the invitation to this meeting are listed.

1. Online platforms on the rise – facts & figures1

     1.1. Types of platforms
              Currently four different types of platforms operating in the travel market which are working
                 in increasingly interdependent ways
              OTAs act as gateways to other websites and apps, as intermediaries and as sellers of
                 services

          1.1.1. Search engines (e.g. Google)
                       Business model: gateway to customer interaction in world wide web
                       Pricing models:
                              o Google adverts  selling advertising (Google AdWords)
                              o Google hotels  charging commission for the bookings

          1.1.2. OTAs (e.g. Priceline2 or Expedia)
                       Business model: allowing customers to search, compare and book for
                           accommodation and other products (e.g. car rental)
                       Pricing model: charging commission for the total price of the total bookings
                           (additional commission for preferential placement)

1
  For more detailed information see: Deloitte: “The Hotel Cooperation Deloitte’s vision on challenges in the hotel business”, available
online under: http://www2.deloitte.com/nl/nl/pages/consumentenmarkt/articles/the‐hotel‐cooperation.html”, last accessed at:
13/09/2016.
2
   Nijjar, Palbir: “Priceline Group Inc: This Incredible Growth Story Is Far From Over”, in: The Motely Fool, available online under at:
http://www.fool.com/investing/general/2016/01/15/priceline‐group‐inc‐this‐incredible‐growth‐story‐i.aspx, last accessed at:
10/09/2016.

1
1.1.3. Metasearch platforms (e.g. Trivago and TripAdvisor)
                      Business model: searching and comparing prices offered across different OTAs
                        and suppliers
                      Pricing model: cost per click + standard advertising
                            o Metasearch players moved into booking space themselves – contradicting
                                 with suppliers for inventory or third party sellers
                            o Example for cross‐marketing: TripAdvisor has signed a deal with
                                 Booking.com to allow customers to book rooms directly on the
                                 TripAdvisor site3

         1.1.4. Disruptive accommodation platforms (e.g. Airbnb, Wimdu)
                       Business model: allowing customers to search, compare and book (private)
                          accommodation
                       Pricing model: charging commission for the total price of the total bookings
                              o Airbnb has become attractive for operators seeking to avoid the rising fees
                                of other OTAs due to lower commission
                              o Airbnb charges a universal 3% “host booking fee”4
                              o Regulatory issues5

2. Current industry structure

    2.1. High concentration of OTA market

        Many well‐known brands owned by just two companies – Priceline Group (60 % of all bookings in
         Europe) and Expedia (75 per cent of the market share in the US through its Orbitz acquisition)6
               o Sub‐brands of Priceline Group: Booking.com, Agoda.com, Ctrip.com
               o Sub‐brands of Expedia: Hotwire, Hotels.com, Venere, Travelocity, Wot if, Ebookers.com,
                  Orbitz, elong.com7
               o Hostelworld next to Booking.com main OTA for youth travel accommodation market8
        It is expected that by 2020 Priceline Group and Expedia will control 94 per cent of all global online
         hotel bookings9

3
  TripAdvisor: “TripAdvisor and The Priceline Group Announce Instant Booking Partnership”, Press release, available online under:
http://ir.tripadvisor.com/releasedetail.cfm?ReleaseID=936592, last accessed at: 13/09/2016.
4
  Epstein, Ellie: “Hostels Embrace Airbnb in Effort to Escape Rising Booking Fees”, in: Mashable.com, available online under:
http://mashable.com/2014/07/19/airbnb‐hostels/#IdmirYx8DGqI from 16 July 2016, last accessed at: 14/09/2016.
5
  Kong, David: “Hoteliers should be concerned about Airbnb”, in: Hotel News Now from 09 July 2015 available online under:
http://www.hotelnewsnow.com/Articles/26941/Hoteliers‐should‐be‐concerned‐about‐Airbnb, last accessed at: 16/09/2016; see
also: http://insideairbnb.com/ last accessed at: 10/09/2016.
6
  Gonzalo, Frederic: “The OTA duopoly: Priceline vs Expedia”, in: ehotelier.com, available online under:
http://ehotelier.com/insights/2015/12/16/the‐ota‐duopoly‐priceline‐vs‐expedia/ , last accessed at: 16/09/2016.
7
  Gonzalo, Frederic: “The OTA duopoly: Priceline vs Expedia”, in: ehotelier.com, available online under:
http://ehotelier.com/insights/2015/12/16/the‐ota‐duopoly‐priceline‐vs‐expedia/ , last accessed at: 16/09/2016.
8
  WYSE Travel Confederation: “Booking Soures Report. Analysis of booking sources in the youth travel accommodation industry”,
June 2015, available for purchase online under: https://www.wysetc.org/research/publications/industry‐flash‐survey‐report‐series,
last accessed at: 16/09/2016. A new report will be published in November 2016.

2
    Highly homogeneous OTA market vs. highly fragmented accommodation provider market (in Europe
         60 % of the hotels are independent)  OTAs have huge bargaining power with their ‘suppliers’.10

    2.2. Significant market power

        Ability to rapidly scale  huge OTAs tend to have small payrolls and are less capital intensive than
         business that they intermediate allowing them to achieve significant market power in short periods
         of times.

        Situation occurs where the business of providing a good or a service is significantly less profitable
         than the business intermediating its sale.

3. Current key concerns: Anti‐competitive and misleading commercial practices

    •    Dysfunctional market: broad and narrow rate parity clauses

    •    Bargaining power of OTAs: even without rate parity, risk that OTAs drop suppliers in their ranking or
         altogether if they do not stick to competitive price.

    •    Persistence of availability parity (minimum bed clause) & terms and agreement parity

    •    Unilateral contract alterations: risk of unilateral contract alterations and short notice period of
         proposed changes to relationship with operators

    •    Non‐transparency on commission levels and commission for unreceived business in terms of
         cancellations

    •    Control of online environment: search results based on price, level of commission paid by the
         supplier to the site, conversion and ‘competitive rate’

    •    Unclear cancellation responsibilities: guests want operator to cancel their bookings, but all dealings
         in the booking process are often with OTAs  might cause bad reviews for operators

    •    Brand usage without permission: OTAs advertising using the hostel name to get higher Google
         search rankings, buying up domain names that resemble the hostel name and invest massively in
         buying keywords to get travellers to shop on their websites (e.g. “hostel”).

    •    Marketing disincentive for suppliers to innovate to reach out to customers since it is difficult to
         compete with the online presence of OTAs

    •    Lock‐in effect: Not providing Email addresses of guests or credit card information

9
  UK Parliament: Anonymous – Written Evidence (OPLoo86),
http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/eu‐internal‐market‐subcommittee/online‐
platforms‐and‐the‐eu‐digital‐single‐market/written/26642.html#_ftn7, last accessed at: 16/09/2016/.
10
   UK Parliament: Anonymous – Written Evidence (OPLoo86),
http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/eu‐internal‐market‐subcommittee/online‐
platforms‐and‐the‐eu‐digital‐single‐market/written/26642.html#_ftn7, last accessed at: 14/09/2016/.

3
4. Regulation Overview

     4.1. European level

             Online platforms play an increasingly central role in social and economic life and are an
              important part of a thriving internet‐enabled economy.

             On 25 May 2016, the Commission adopted an updated version of the 2009 Guidance on the
              application of the Unfair Commercial Practices Directive.11
              The purpose of this document is to facilitate the proper application of the Unfair Commercial
              Practices Directive (‘the UCPD’). It provides guidance on the UCPD’s key concepts and provisions
              and gives practical examples taken from the case‐law of the Court of Justice of the European
              Union and from national courts and administrations. To facilitate enforcement activities and
              ensure legal certainty, the updated Guidance highlights questions that are common to all
              Member States.

             In 2016 the European Commission has also published principles which will hold OTAs to account
              for the common practice of providing a seemingly impartial recommendation which is in fact
              linked to commissions and the position in the search ranking.12

             As part of the Digital Single Market Strategy, the European Commission conducted a
              comprehensive assessment of the role of online platforms. This assessment was based on a
              broad public consultation13, and a series of workshops and studies.

             One testimony by anonymous source (assumed hotelier that has business in Europe) on
              complaints it has against the big OTAs particularly Priceline & Expedia.14

             The results of the assessment are further set out in a Staff Working Document on Online
              Platforms15 that also underpins the Platforms Communication16 which:
                  o formulates the Commission's policy approach to online platforms; and
                  o Identifies areas where action or further assessment may be necessary.

11
   European Commission: Guidance on the Implementation/Application of Directive 2005/29/EC On Unfair Commercial Practice
(Brussels, 25.5.2016 SWD(2016) 163 final, available under: http://ec.europa.eu/justice/consumer‐
marketing/files/ucp_guidance_en.pdf , last accessed: 15/09/2016.
12
   European Commission: Key principles for comparison tools, available online under:
http://ec.europa.eu/consumers/consumer_rights/unfair‐trade/docs/key_principles_for_comparison_tools_en.pdf, last accessed at:
13/09/2016.
13
   European Commission: Public Consultation regulatory environment platforms online intermediaries data and cloud,
https://ec.europa.eu/digital‐single‐market/en/news/public‐consultation‐regulatory‐environment‐platforms‐online‐intermediaries‐
data‐and‐cloud
14
   UK Parliament: Anonymous – Written Evidence (OPLoo86),
http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/eu‐internal‐market‐subcommittee/online‐
platforms-and-the-eu-digital-single-market/written/26642.html#_ftn7, last accessed at: 14/09/2016/.
15
   European Union: Digital Single Market: https://ec.europa.eu/digital‐single‐market/news‐redirect/31576
16
   http://eur‐lex.europa.eu/legal‐content/EN/TXT/?qid=1466514160026&uri=CELEX:52016DC0288

4
   The Commission will also further assess the necessity of targeted policy measures (regulatory,
            self‐ or co‐regulatory) on the basis of clearly identified problems relating to a specific type or
            activity of online platforms, and in‐depth evaluation of the sufficiency and adequacy of existing
            regulatory framework.
           In formulating its policy response to online platforms, the Commission will be guided by the
            following four principles:
                 o A level playing field for comparable digital services;
                 o Ensuring that online platforms behave responsibly to protect core values;
                 o Fostering trust, transparency and ensuring fairness;
                 o Keeping markets open and non‐discriminatory to foster a data‐driven economy.

    4.2. National level – Broad rate parity abolished

           Italy, France and Swedish authorities coordinated their investigations and on 21 April 2015
            adopted parallel decisions accepting identical commitments from the leading OTA
            Booking.com and making them binding in their respective jurisdiction.

           In 2015, Booking.com and Expedia voluntarily omitted to remove ‘broad’ rate parity clauses in
            contracts with hotels throughout Europe which prevented hotels from offering cheaper rates to
            other OTAs.

           Narrow parity clause continue to persists in many markets which prevents hotels from offering
            cheaper rates publicly on their own websites (exception Closed User Group)

           France:
                o France has outlawed all rate parity clauses in the hotel sector as part of the ‘Marcon
                    Law’ (9 July 2015)

           Germany:
               o Regulators at German Federal Cartel Office sent a cease‐and‐desist letter to
                  Booking.com and ruled against Booking.com ‘narrow rate parity’ clauses (02 April 2015)

           Italy:
                 o   Italian Chamber of Deputies approved the ‘Article 50’ draft law banning ‘narrow’ rate
                     parity (7 October 2015)
                o    The Italian Parliament voted 434:4 against rate parity clauses in OTA contracts with
                     hotels.

           Sweden:
               o Swedish Competition Authority closed its investigation into Expedia due to the company
                  voluntarily changing its contract commitments with hotels in a similar way to

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Booking.com – Expedia can no longer stop operatprs from offering other OTAs the same
                        price or a lower one (broad rate parity)

             UK:
                    o   Broad rate parity banned, narrow rate parity remains: In 2015, the UK Competition and
                        Markets Authority banned ‘wide MFN’ clauses in the market for car insurance. This stops
                        price comparison websites (PCWs) and car insurers from signing exclusive deals to offer
                        lower prices. This was an effort to ensure there is greater competition between PCWs.
                        PCWs can still stipulate that the provider is not allowed to undercut them in the direct
                        channel.

                    o   The UK CMA has closed its own investigation into hotel bookings, saying that it will
                        monitor activity for the next twelve months and await further European developments
                        (situation now unclear due to Brexit)

     4.3. Other markets (a more comprehensive report to follow)17

             United States
                  o In the United States, rate‐parity agreements came under heavy scrutiny in 2015.
                     Approximately 30 lawsuits were filed in multiple states against major hoteliers
                     consolidated in federal court, alleged that rate‐parity agreements between OTAs and
                     hotels violated antitrust laws as well as state consumer protection statute

                    o   The suits were all dismissed because the Department of Justice found that, in reality, a
                        perfectly regulated and unregulated market may look the same  Rate parity still in
                        place

             Australia
                 o September 2016: Booking.com and Expedia have abolished their broad rate parity but
                      stick to narrow rate parity (between operator and OTA)18

17
   For more information see Scott, Ilse: Rate parity’s legal landscape, in: Hotel News Now from 12 August 2015, available online
under: http://www.hotelnewsnow.com/Articles/27374/Rate‐paritys‐legal‐landscape, last accessed at: 16/09/16.
18
   STAY WYSE: Booking.com and Expedia Soften Rate Parity Stance in Australia http://www.staywyse.org/2016/09/01/booking‐
com‐softens‐rate‐parity‐stance‐in‐australia/, last accessed at” 12/09/2016.

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5. Current Sydney Declaration

Agreements between OTAs and youth travel accommodation operators should not contain clauses that:

    1.    Allow the use of property or brand names in online advertising, unless specifically authorised;
    2.    Require rate parity;
    3.    Enforce mandatory availability parity (either via last room availability or minimum allocations);
    4.    Allow for agreements to be terminated at short notice (without a compelling cause), with no
          consultation and without being signed by both parties;
    5.    Are not written in plain English (and are not translated into the main official language of the
          operator);
    6.    Conflict with national or international trade, competition or consumer laws;
    7.    Require operators to indemnify OTAs for tax obligations on commissions;
    8.    Allow the OTAs to be opaque in how they display default search results (including the use of
          spurious ”recommended” terms that are designed to mislead consumers, when the basis of
          recommendation is the % commission paid or the availability given to the OTA);
    9.    Result in commissions being paid on no shows or any other unrealised turnover.
    10.   Discriminate against an operator based on size or location.

    Next steps with regards to Sydney Declaration:

              •   Option A:
                     • Launching a comprehensive survey about the relationship between OTAs and youth
                         travel accommodation operators – incorporating feedback of roundtable meeting
                         (November 2016)
                     • Drafting report based on survey (January 2017)
                     • Follow‐Up Distribution Panel Discussion during STAY WYSE Conference including all
                         relevant stakeholders (operators and OTAs) (February 2017)
                     • Updating current Sydney declaration (code of conduct/best practice guide) based
                         on roundtable input and on survey findings (March 2017)

              •   Option B:
                              •   Keeping current Sydney declaration  change of wording/adding removing
                                  paragraphs?
                              •   Follow‐Up Distribution Panel Discussion during STAY WYSE Conference
                                  including all relevant stakeholders (February 2017)

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6. Survey results

    6.1. “Supporters say that OTAs and youth travel accommodation (YTA) operators have a mutually
         beneficial relationship and that OTAs play an important role in increasing business. Please name
         the top advantages for your business when working together with an OTA (if any).”

              Billboard effects mentioned 3 times
              Marketing ‐ mentioned 3 times
              Sales ‐ mentioned 3 times
              Filling available spaces
              Customer base
              Translation services
              Increases our reach to new customers
              Helps diversify our residence population
              Full payment in advance
              Broader distribution
              Extended reach of source markets
              Additional sales distribution channels for our hotel business
              Facilitates selling
              Easy to book
              Visibility
              Technology
              New Markets
              Online Appearance
              Reviews
              Fixed provision models
              Volume of booking
              International clients
              OTAs give access to FIT foreign market
              Wider distribution
              Wider reach
              Awareness level
              Loyal customer base
              Exposure to lots of markets and customers
              Greater brand awareness
              Foreign market
              Better insight from more reviews
              Access to new communities of travellers
              Multiple OTAs available through one back office

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6.2. “Critics say that OTAs take advantage of their strong market position and put youth travel
         accommodation operators in a difficult position. Please name the top disadvantages for your
         business when dealing with an OTA (if any).”

              High commission mentioned 12 times
              Rate parity mentioned 4 times
              Ownership and control issues mentioned 10 times
               o Domain grabbing and bidding on own brand name
               o Bidding on our organization name
               o Unlimited PPC funds
               o Ownership of the client in hands of the OTA
               o Misleading Description
               o Less control over reservations
               o Coded Emails
               o They take away your brand
               o Lack of control
               o Targeted Re‐Marketing resulting in high cancellations

              Concentration of power
               o Disparities
               o Monopoly
               o Too much power in the travel market
               o Their large advertising budget

              Other issues mentioned
               o All OTAs work with the same end customers
               o Competitor for our direct bookings
               o Integration is needlessly complicated
               o Channel maintenance is clumsy and difficult
               o Lots of fake bookings for visas

    6.3. “Please summarize your general opinion about the current relationship between OTAs and YTA
         operators.”
             “The OTAs have too much influence and the partnership is too one‐sided.”

              “Necessary evil.”

              “In general OTAs are good, strong and loyal partners for us: OTAs and YTAs have different
               perspectives on general issues of travel market, which make the cooperation tricky.”

              “For small YTA operators every dollar counts. It is fair to pay commission to OTAs but when it
               is too high it will cut into our revenue. And with rate parity and the OTAs large advertising

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budget, it is challenging for YTA operators to drive more direct bookings. And when the
                operators do not use a channel manager, monitoring and updating rates on several channels
                is time consuming.”

               “It is an important relationship but must be managed and monitored closely so
                accommodation providers do not rely solely on OTA business. I also feel very strongly they
                should not be allowed to use google ads to bid on your hostel name and gain business out of
                your good will.”

               “OTAs are undoubtedly a large and vital part of running any youth travel accommodation
                and provide a steady stream of bookings. The problem arises when lack of competition
                means high commission and low level of service and a market that at times appears like an
                oligopoly.”

               “Travel professionals can gain much benefit from integrating with the leading OTAs.
                However, intelligent software is needed to make such integrations possible.”

               “I see it as very valuable – it is to be carefully managed and used to fill your shoulder
                and peak.”

     6.4. “Which other statements would you like to add to a new code of conduct?”

               “I do not support the punishing activities of the OTAs where eg. ‘dimming’ is used if a hotel /
                hostel sells at a lower rate than to the OTAs.”

               ‘We need to address the number of fake bookings that are processed through OTAs.”

               “Additionally, credit card information should be visible/ accessible until check‐in, rather than
                the current 10 days window‐post booking.

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Further readings:

Bujarski, Luke: European OTA Outlook: Regulators, Rivals and Technology Disrupt Status Quo, in: Phocuswright Online
from July 2015, available online: http://www.phocuswright.com/Travel‐Research/European‐OTA‐Outlook‐Regulators‐
Rivals‐and‐Technology‐Disrupt‐Status‐Quo, last accessed at: 14/09/2016.

Baker, Terence: Europe regulators put pressure on rate parity, in: Hotel News Now from 12 January 2015, available
online under: http://www.hotelnewsnow.com/Articles/24804/Europe‐regulators‐put‐pressure‐on‐rate‐parity, last
accessed at: 14/09/2016.

Buyingbusinesstravel.com: Analysis – Is it the end for ‘rate parity’ in hotels? 27 November 2015, 13 November 2015
https://buyingbusinesstravel.com/feature/2725006‐analysis‐it‐end‐%E2%80%98rate‐parity%E2%80%99‐hotels

Deloitte: “The Hotel Cooperation Deloitte’s vision on challenges in the hotel business”, available online under:
http://www2.deloitte.com/nl/nl/pages/consumentenmarkt/articles/the‐hotel‐cooperation.html”, last accessed at:
12/09/2016.

Epstein, Ellie: Hostels Embrace Airbnb in Effort to Escape Rising Booking Fees, available online under:
http://mashable.com/2014/07/19/airbnb‐hostels/#IdmirYx8DGqI from 16 July 2016, last accessed at:14/09/2016 and:
Valtr, Richard: “Hostels – The marriage of Airbnb and Hotels?” from 28 June 2016

European Parliament: Anonymous – Written Evidence (OPLoo86),
http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/eu‐internal‐market‐
subcommittee/online‐platforms‐and‐the‐eu‐digital‐single‐market/written/26642.html#_ftn7, last accessed at:
16/09/2016/.

European Commission: Online Platforms and the Digital Single Market. Opportunities and Challenges for Europe, Com
(2016) Brussels 25.06.2016 , available online under: http://www.politico.eu/wp‐content/uploads/2016/04/Platforms‐
Communication.pdf, last accessed at: 14/09/2016.

European Commission: Key principles for comparison tools, available online under:
http://ec.europa.eu/consumers/consumer_rights/unfair‐trade/docs/key_principles_for_comparison_tools_en.pdf, last
accessed at: 13/09/2016.

Freed, Jason Q: Rate Parity Issues Keep Hotel Lawyers Busy, available online under: http://duettoresearch.com/rate‐
parity‐issues‐keep‐hotel‐lawyers‐busy/, last accessed at:

Gaggioli, Alex: Analysis of Major Online Travel Agencies – OTAs, in: Cloudbeds Blog, available online under:
https://www.cloudbeds.com/articles/analysis‐of‐major‐online‐travel‐agencies‐otas/, last accessed at: 14/09/2016.

Gonzalo, Frederic: “The OTA duopoly: Priceline vs Expedia”, in: ehotelier.com
http://ehotelier.com/insights/2015/12/16/the‐ota‐duopoly‐priceline‐vs‐expedia/ , last accessed at: 16/09/2016.

O’Neil, Sean: “As rate parity falters, what OTAs and hotels may do next”, in: Tnooz Online, available online under:
https://www.tnooz.com/article/as‐rate‐parity‐falters‐what‐otas‐and‐hotels‐may‐do‐next/, last accessed at:
13/09/2016.

Pritchard, Elliott: Rate parity: The Good, the Bad and the Ugly, in: Triptease Blog, available online under:
http://www.triptease.com/rate‐parity‐good‐bad‐ugly/, last accessed at: 14/09/2016.

Perkins, Carina: Independent hotels still unhappy with OTAs, in: Big Hospitability Online from 17 February 2014,
available online under: http://www.bighospitality.co.uk/Business/Independent‐hotels‐still‐unhappy‐with‐OTAs, last
accessed at: 13/09/2016.

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Nijjar, Palbir: Priceline Group Inc: This Incredible Growth Story Is Far From Over, in: The Motely Fool, available online
under at: http://www.fool.com/investing/general/2016/01/15/priceline‐group‐inc‐this‐incredible‐growth‐story‐i.aspx,
last accessed at: 10/09/2016.

Kong, David: Hoteliers should be concerned about Airbnb, in: Hotel News Now from 09 July 2015 available online
under: http://www.hotelnewsnow.com/Articles/26941/Hoteliers‐should‐be‐concerned‐about‐Airbnb, last accessed at:
16/09/2016; see also: http://insideairbnb.com/ last accessed at: 10/09/2016.

Scott, Ilse: Rate parity’s legal landscape, in: Hotel News Now from 12 August 2015, available online under:
http://www.hotelnewsnow.com/Articles/27374/Rate‐paritys‐legal‐landscape, last accessed at: 16/09/16.

Tnooz: Why do consumers prefer booking with online travel agencies? https://www.tnooz.com/article/consumers‐
prefer‐online‐travel‐agencies/

Tnooz: What happens if the hotel industry finally says RIP to rate parity? Jul 24, 2012
https://www.tnooz.com/article/what‐happens‐if‐the‐hotel‐industry‐finally‐says‐rip‐to‐rate‐parity/

TripAdvisor: TripAdvisor and The Priceline Group Announce Instant Booking Partnership, Press release, available online
under: http://ir.tripadvisor.com/releasedetail.cfm?ReleaseID=936592, last accessed at: 13/09/2016.

Ricca, Stephanie: OTAs gaining bargaining power – now what?, in: Hotel News Now from 6 May 2015, available online
under: http://www.hotelnewsnow.com/Articles/25980/OTAs‐gaining‐bargaining‐powernow‐what, last accessed at:
14/09/2016.

Phocuswright: Asia Pacific Inline Travel Overview Wight Edition: Online Travel Agencies, available online under:
http://www.phocuswright.com/Travel‐Research/Asia‐Pacific‐Online‐Travel‐Overview‐Eighth‐Edition‐Online‐Travel‐
Agencies, last accessed at: 15/09/2016.

Phocuswright: U.S. Online Travel Agencies 3Q15: And Then There Were Two, available online under:
http://www.phocuswright.com/Travel‐Research/Market‐Overview‐Sizing/U‐S‐Online‐Travel‐Agencies‐3Q15‐And‐Then‐
There‐Were‐Two, last accessed at: 15/09/2016.

UK Parliament: Anonymous – Written Evidence (OPLoo86),
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