Civil Law and Airline Alliance Agreement Disputes in Europe

1. Introduction

Airline alliance agreements are long-term cooperation arrangements between airlines. They may involve:

code-sharing;

joint scheduling;

coordinated fares;

revenue sharing;

joint marketing;

frequent-flyer programmes;

airport facilities;

common sales systems;

capacity coordination;

joint ventures; and

coordinated network planning.

The major European alliances include arrangements associated with Star Alliance, SkyTeam and oneworld, although the legal structure differs from one alliance to another.

From a civil-law perspective, an airline-alliance dispute can therefore involve contract law, breach of cooperation obligations, termination, damages, good faith, interpretation of contractual clauses, passenger claims and allocation of liability. At the same time, alliance agreements have a major competition-law dimension because cooperation between competitors can reduce independent competition.

A particularly important European authority is Deutsche Lufthansa AG v European Commission, where the General Court examined the Lufthansa–SAS bilateral alliance agreement, joint venture agreement and codeshare arrangements in detail. The Court expressly distinguished the scope and purpose of an alliance agreement from a codeshare agreement. (Infocuria)

Important qualification: there is relatively little reported European case law involving a purely private civil action for breach of an airline-alliance agreement. Consequently, the most useful authorities include direct alliance cases, competition cases concerning alliance arrangements, and CJEU cases concerning code-sharing and allocation of contractual/operating-carrier responsibilities.

2. Meaning of an Airline Alliance Agreement

An airline alliance agreement is a contractual framework under which otherwise separate airlines agree to cooperate in selected commercial or operational areas.

For example:

Airline A and Airline B remain separate companies but agree to sell seats under each other's flight codes, coordinate schedules and provide reciprocal frequent-flyer benefits.

A more integrated arrangement may involve:

common pricing + network planning + capacity coordination + revenue sharing + joint marketing.

The legal consequences become more significant as the degree of integration increases.

The European Commission's historical examination of the Lufthansa–SAS–United alliance shows that alliance agreements can cover route and schedule planning, marketing, distribution, code-sharing, pricing, inventory and yield management, revenue sharing, IT systems and airport facilities. (EUR-Lex)

3. Main Types of Alliance Disputes

An alliance dispute may arise from:

A. Breach of contractual obligations

One airline may fail to perform an agreed obligation.

B. Wrongful termination

An airline may terminate the alliance before the contractual termination date.

C. Failure to provide capacity

A partner may reduce flights contrary to agreed commitments.

D. Pricing disputes

Partners may disagree over fares, revenue allocation or commission.

E. Code-share disputes

One airline may sell seats under another airline's code, creating questions about responsibility.

F. Revenue-sharing disputes

The parties may disagree about how ticket revenue should be divided.

G. Schedule coordination

Changes to flight schedules may affect the commercial balance of the alliance.

H. Passenger liability

A passenger may not know whether to sue the ticketing airline or the airline actually operating the flight.

I. Competition-law disputes

An alliance can potentially restrict competition contrary to Article 101 TFEU.

J. Merger-related disputes

An alliance may cause the parties to be treated as less independent competitors during merger review.

4. Legal Framework in Europe

Several legal regimes may apply simultaneously.

4.1 Contract law

The governing national law of the alliance agreement determines matters such as:

formation;

interpretation;

breach;

termination;

damages;

force majeure;

good faith;

limitation of liability;

indemnities.

The agreement should therefore contain a carefully drafted governing-law clause.

4.2 EU competition law

The central provision is:

Article 101 TFEU

It addresses agreements between undertakings that have the object or effect of preventing, restricting or distorting competition.

This is particularly important because airlines that are competitors may agree on:

fares;

capacity;

schedules;

routes;

customers;

revenue sharing.

The European Commission historically examined the Lufthansa–SAS–United alliance under the predecessor to Article 101 and initially considered that the cooperation could infringe European competition rules. (EUR-Lex)

4.3 Merger control

Even where airlines do not merge, an alliance can affect merger analysis.

If extensive cooperation means that alliance partners have little incentive to compete independently, their commercial relationship may become relevant to the competitive assessment of another transaction.

That principle was central to the Lufthansa/Swiss proceedings. (Infocuria)

4.4 Passenger-rights law

Regulation 261/2004 becomes particularly important in code-sharing and alliance arrangements.

The key question can be:

Who is the legally responsible operating air carrier?

This question is not always answered simply by looking at the airline that sold the ticket.

5. Case Law

Case 1: Deutsche Lufthansa AG v European Commission, T-712/16

General Court, 16 May 2018

This is one of the most important cases for the subject.

Lufthansa was a member of Star Alliance and had several agreements with SAS, including:

a Bilateral Alliance Agreement;

a codeshare agreement;

a marketing and sales agreement; and

a joint venture agreement.

The Bilateral Alliance Agreement provided the basis for extensive cooperation between Lufthansa and SAS.

The Court noted that the alliance arrangement involved matters such as joint pricing policy, network and flight planning, hub organisation and marketing strategy. (Infocuria)

Lufthansa later sought a waiver of certain competition-related commitments after terminating the joint venture with SAS.

The General Court held that the Commission had not adequately examined the consequences of those contractual changes.

Importantly, the Court distinguished:

the bilateral alliance agreement;

the joint venture agreement; and

the codeshare agreement.

The Court observed that these agreements had different scope, content and contracting parties. (Infocuria)

Principle

Termination or modification of one part of an airline alliance cannot automatically be treated as termination of the entire commercial relationship.

Each agreement must be examined according to:

its wording;

purpose;

parties;

commercial scope; and

effect on competition.

This is highly relevant to private contractual disputes.

6. Case 2: Lufthansa/SAS/United Airlines Alliance

European Commission, alliance proceedings concerning COMP/D-2/36.201, 36.076 and 36.078

Although this is a Commission proceeding rather than a private civil judgment, it is a foundational European authority concerning airline alliances.

The Commission examined:

Lufthansa–United cooperation;

SAS–United cooperation; and

the tripartite Lufthansa/SAS/United coordination agreement.

The agreements were designed to create long-term cooperation while the airlines remained separate corporate entities.

They covered:

routes;

schedules;

marketing;

sales;

distribution;

branding;

code-sharing;

pricing;

inventory;

revenue sharing;

frequent-flyer programmes; and

airport facilities. (EUR-Lex)

The Commission initially considered that the agreements raised concerns under European competition law and subsequently considered commitments proposed by the parties. (EUR-Lex)

Principle

An airline alliance is not legally immune merely because each airline remains a separate corporation.

The substance of the cooperation matters.

7. Case 3: Deutsche Lufthansa AG v European Commission, T-712/16 — Alliance Termination and Codeshare Distinction

This case deserves separate treatment for another important proposition.

The Court specifically considered the termination of Lufthansa's joint venture with SAS and the continuing contractual relationship.

The evidence showed that termination of the joint venture did not necessarily terminate all cooperation because the broader Bilateral Alliance Agreement remained relevant. (EUR-Lex)

The Court also observed that the later Swiss–SAS codeshare was different from the Lufthansa–SAS alliance arrangement.

Civil-law significance

In an alliance dispute, a court should examine each contractual instrument separately.

For example:

Agreement A: global alliance
Agreement B: codeshare
Agreement C: marketing agreement
Agreement D: joint venture
Agreement E: revenue-sharing agreement

Termination of Agreement D does not necessarily terminate A, B or C.

This principle is particularly important when an airline claims that an alliance has ended.

8. Case 4: Austrian Airlines / Lufthansa Group and Star Alliance Arrangements

The European Commission's Lufthansa/Swiss merger assessment examined the effect of Lufthansa's extensive bilateral agreements with Star Alliance partners.

The Commission concluded that the cooperation with certain partners was sufficiently extensive that those partners could not simply be treated as ordinary independent competitors of Lufthansa.

The arrangements included cooperation concerning:

pricing;

network planning;

flight planning;

hubs;

marketing; and

broader commercial integration. (EUR-Lex)

Principle

The degree of contractual integration matters.

A basic code-share arrangement may have a substantially different legal and competitive effect from a worldwide alliance involving joint pricing and network planning.

9. Case 5: SAS Cargo Group and Others v European Commission, T-324/17 / C-403/22 P

This case concerns the airfreight side of airline cooperation.

The General Court considered evidence concerning contacts between SAS and Lufthansa and referred to an earlier exemption involving the Lufthansa/SAS general alliance agreement.

The alliance had provided for a worldwide joint pricing policy and extensive integration of freight services. (EUR-Lex)

The later proceedings concerned alleged coordination of airfreight prices.

The case ultimately reached the Court of Justice, which delivered judgment in C-403/22 P on 26 February 2026. (EUR-Lex)

Principle

A contractual alliance does not create a blanket exemption from competition law.

Even if cooperation was previously accepted or exempted in some form, later conduct must still be examined under the applicable competition rules.

10. Case 6: Singapore Airlines and Singapore Airlines Cargo v Commission, C-379/22 P

Court of Justice, 26 February 2026

This case is particularly useful because the airlines were members of the WOW commercial alliance.

The alliance included:

Singapore Airlines;

Lufthansa;

SAS Cargo; and

Japan Airlines.

The proceedings concerned alleged coordination of airfreight pricing and related conduct. (EUR-Lex)

The Court considered issues including:

participation in a single and continuous infringement;

conduct occurring within a commercial alliance;

territorial jurisdiction;

limitation periods; and

the legal significance of coordinated conduct.

Principle

Being part of a commercial alliance does not itself establish liability for every action of every alliance member.

But evidence of coordinated conduct within the alliance can be legally relevant when establishing participation in unlawful cooperation.

11. Case 7: British Airways v Commission, T-341/17; C-378/22 P

This is an airfreight competition case rather than a conventional passenger-alliance contract dispute.

The General Court examined allegations concerning coordinated pricing behaviour among airlines.

The case involved a Commission finding of a single and continuous infringement involving coordination of elements of airfreight prices. (Infocuria)

The case subsequently reached the Court of Justice, which delivered judgment on 26 February 2026. (Infocuria)

Principle

For alliance-related litigation, courts may examine whether apparently separate contacts form part of a broader coordinated scheme.

This is particularly relevant where several alliance contracts, meetings, pricing arrangements and communications are alleged to form one coordinated commercial arrangement.

12. Case 8: United Airlines, C-561/20

CJEU, 7 April 2022

This is one of the most important cases for code-sharing and alliance passenger disputes.

Passengers purchased a single reservation from Lufthansa for travel from Brussels to San José, with a stopover in Newark.

United Airlines operated the entire journey, although it was not the contractual carrier that sold the ticket.

The final destination was reached with a delay of 223 minutes.

The CJEU held that an operating carrier can be responsible under Regulation 261/2004 even where it does not have the passenger's direct contract of carriage. The Court also recognised that the operating carrier may subsequently seek recovery from third parties under applicable national law. (curia)

Principle

There can be a distinction between:

Contractual carrier

and

Operating air carrier.

This distinction is crucial in airline alliances.

13. Case 9: KLM Royal Dutch Airlines, C-367/20

This case concerned connecting flights covered by a single reservation and the responsibility of carriers under Regulation 261/2004.

The CJEU proceedings concerned the interaction between:

connecting flights;

the contractual reservation;

the operating carrier; and

passenger compensation. (Infocuria)

Principle

A passenger's legal position cannot always be determined simply by asking which airline issued the ticket.

The structure of the journey and the identity of the operating carrier must also be examined.

This is particularly important where alliance partners operate different legs.

14. Case 10: Transportes Aéreos Portugueses (TAP), C-74/19

CJEU, 11 June 2020

This case concerned Regulation 261/2004 and the concept of extraordinary circumstances.

The dispute arose after disruptive passenger behaviour affected an aircraft's operation and caused consequences for a subsequent flight.

The CJEU considered:

extraordinary circumstances;

reasonable measures;

effects on subsequent flights; and

the responsibility of the operating carrier. (Infocuria)

Alliance significance

In a multi-airline network, disruption to one flight can affect another flight operated by the same or a partner carrier.

Therefore, alliance partners must carefully allocate operational responsibility and indemnity obligations.

15. Case 11: Transportes Aéreos Portugueses, C-74/19 — Network Effects

The case is also important from a contractual-risk perspective because the CJEU recognised that an extraordinary event affecting an earlier flight can have consequences for a later flight.

The Court examined whether the carrier could rely on that earlier event and what reasonable measures it was expected to take. (curia)

Principle

Alliance agreements should therefore contain detailed provisions concerning:

aircraft substitution;

delays;

missed connections;

disruption;

rerouting;

passenger assistance;

allocation of costs.

16. Contractual Duties in an Airline Alliance

The parties should normally specify the following obligations.

16.1 Schedule obligation

The agreement may require each airline to operate agreed frequencies.

A dispute can arise if:

Airline A withdraws three weekly flights without contractual justification.

The other airline may claim:

breach of contract;

lost revenue;

additional operational expenses;

contractual penalties.

16.2 Capacity obligation

The agreement may establish minimum seat capacity.

Failure to provide the agreed capacity may undermine the commercial assumptions of the alliance.

16.3 Code-share obligation

A partner may be required to make seats available to the other airline.

A dispute may arise where:

inventory is withheld;

booking classes are incorrectly opened;

codes are removed;

schedules change without notice.

17. Revenue-Sharing Disputes

Revenue-sharing is one of the most important sources of potential disputes.

Suppose:

Airline A sells the ticket;

Airline B operates the aircraft;

Airline C provides a connecting flight.

The alliance agreement may specify how revenue is divided.

A dispute can arise over:

ticket price;

taxes;

airport charges;

commissions;

refunds;

currency conversion;

ancillary revenue;

frequent-flyer costs.

The contract should therefore provide a clear accounting mechanism.

18. Pricing Disputes

Alliance partners may cooperate commercially, but pricing cooperation is particularly sensitive.

An agreement may contain:

joint fare-setting;

revenue management;

coordinated fare classes;

corporate discounts.

However, extensive coordination between competitors can raise Article 101 TFEU issues.

The historical Lufthansa/SAS/United proceedings demonstrate why pricing provisions in alliance agreements receive close scrutiny. (EUR-Lex)

19. Good Faith

Good faith can become relevant where one airline technically complies with the wording of an agreement but undermines its commercial purpose.

Example:

Airline A agrees to promote Airline B's connecting flights but systematically gives priority to another partner.

Depending on the applicable national law and contract wording, the conduct may generate a dispute over:

contractual good faith;

implied duties;

cooperation obligations;

abuse of contractual rights.

However, the exact scope of good faith depends on the governing law.

20. Termination of Alliance Agreements

Termination provisions should address:

Ordinary termination

Termination after a specified notice period.

Termination for breach

For example:

non-payment;

failure to operate;

confidentiality breach;

regulatory violation.

Regulatory termination

Termination where continuation becomes unlawful.

Insolvency termination

A party becomes insolvent.

Change of control

One airline is acquired.

Force majeure

Long-term operational impossibility.

Competition-law termination

Continuation of the agreement creates unacceptable competition-law risk.

21. The Lufthansa–SAS Example: Why Termination Matters

The Lufthansa/SAS litigation provides an excellent illustration.

Lufthansa terminated its joint venture with SAS in 2013 but continued to have other contractual relationships with SAS.

The Court noted that the termination of the JV changed the contractual relationship, but the continuing alliance arrangements remained relevant to the overall assessment. (EUR-Lex)

Legal lesson

Termination of one alliance component does not necessarily equal termination of the alliance relationship as a whole.

22. Codeshare Versus Alliance Agreement

These concepts should not be confused.

The General Court specifically emphasised these differences in the Lufthansa/SAS litigation. (Infocuria)

23. Passenger Claims in Alliance Arrangements

An alliance can create a complicated contractual chain:

Passenger → Travel agent → Ticketing airline → Alliance partner → Operating airline

The passenger may therefore be unsure who is responsible.

Under EU passenger-rights jurisprudence, the identity of the operating air carrier can be decisive.

The United Airlines judgment demonstrates that the operating carrier may be liable even without being the passenger's contractual carrier. (curia)

24. Indemnification Between Alliance Partners

An alliance agreement should ideally specify:

If Airline B pays a passenger compensation caused by Airline A's breach, Airline A must reimburse Airline B.

This creates an internal contractual allocation of risk.

For example:

Passenger → claims United

Then:

United → contractual indemnity claim against Lufthansa/another partner

The CJEU's United Airlines judgment expressly recognised the possibility of the operating carrier seeking compensation from third parties under applicable national law. (curia)

25. Competition Law and Civil Liability

A particularly important distinction is:

Public enforcement

The European Commission or national competition authorities may investigate an alliance.

Private enforcement

A customer, competitor or other injured party may potentially seek damages under applicable competition-law rules.

Contractual enforcement

An alliance partner may sue another partner for breach.

These are legally different proceedings.

One does not automatically determine the outcome of the others.

26. When an Alliance Can Create Competition Problems

Risk increases where competitors coordinate:

prices;

capacity;

schedules;

routes;

customers;

output;

revenue.

The Lufthansa/SAS/United alliance illustrates the scale of cooperation that can attract competition-law scrutiny. (EUR-Lex)

By contrast, a limited code-share may involve considerably less integration.

Therefore, the analysis should always ask:

What exactly have the airlines agreed to coordinate?

27. Relevant Market

Competition analysis may examine individual origin-and-destination markets.

For example:

Frankfurt–Chicago;

Frankfurt–New York;

Paris–New York;

Amsterdam–New York.

The Commission's historical Lufthansa/SAS/United analysis specifically identified hub-to-hub origin-and-destination markets affected by the alliance. (EUR-Lex)

28. Disputes About Customer Allocation

An alliance agreement may contain provisions concerning:

corporate customers;

travel agencies;

frequent flyers;

cargo customers;

loyalty programmes.

A dispute can arise where one partner alleges that another diverted customers contrary to the agreement.

However, customer allocation provisions themselves may raise competition concerns where they substantially restrict independent competition.

29. Loyalty Programmes

Alliance partners frequently cooperate on frequent-flyer programmes.

Potential civil disputes include:

incorrect mileage credits;

failure to honour benefits;

lounge-access disputes;

status recognition;

cancellation of benefits.

The underlying question may be whether the passenger has:

a contractual claim against the airline;

a claim against the loyalty-programme operator; or

a consumer-protection claim.

30. Confidentiality

Alliance agreements usually contain extensive confidential information.

Examples include:

pricing information;

passenger data;

business plans;

capacity information;

route strategies;

customer data;

revenue data.

A breach can result in:

contractual damages;

injunctions;

termination;

regulatory consequences.

31. Data Protection

Alliance arrangements may require airlines to exchange passenger information.

European data-protection rules therefore become relevant.

Particular issues include:

controller/processor status;

lawful basis;

international transfers;

passenger information;

loyalty-programme data;

data retention;

cybersecurity.

A contract should allocate responsibility for data breaches between alliance members.

32. Intellectual Property and Branding

Airline alliances often involve:

logos;

trademarks;

joint marketing;

co-branding;

advertising materials.

Disputes may arise after termination.

For example:

Airline A terminates its alliance with Airline B but continues using B's branding.

Possible remedies may include:

injunction;

damages;

account of profits;

contractual penalties.

33. Force Majeure

Airline alliances are particularly vulnerable to:

pandemics;

wars;

airspace closures;

airport closures;

government restrictions;

strikes;

natural disasters.

The contract should define whether force majeure excuses:

flight obligations;

minimum capacity;

revenue-sharing obligations;

marketing obligations;

schedule commitments.

34. Dispute Resolution

Large airline alliances commonly require sophisticated dispute-resolution clauses.

The agreement may provide for:

negotiation;

mediation;

arbitration;

institutional arbitration;

expert determination;

court proceedings.

Important drafting issues include:

seat of arbitration;

governing law;

language;

emergency relief;

confidentiality;

interim measures;

expert determination for accounting disputes.

35. Applicable Law

Because airlines operate internationally, the agreement may involve several legal systems.

For example:

Airline A — Germany
Airline B — France
Airline C — United States
Flight — Netherlands
Passenger — Spain

The contract should clearly establish:

governing law + jurisdiction/arbitration + contractual definitions.

Otherwise, preliminary disputes over applicable law can become expensive.

36. Damages

A civil claim arising from breach of an alliance agreement may potentially involve:

Direct losses

Actual additional expenditure.

Lost revenue

Revenue that would have been generated.

Lost profits

Subject to applicable legal requirements concerning proof and remoteness.

Operational costs

Additional aircraft, staffing or handling costs.

Passenger compensation

Where contractual indemnification exists.

Regulatory losses

Subject to the applicable legal framework and contractual allocation.

37. Causation

The claimant normally needs to establish a connection between:

breach → loss

Example:

Airline B failed to provide agreed connecting capacity → Airline A lost corporate customers → Airline A claims damages.

The difficult question may be whether the loss was actually caused by the breach or by:

market conditions;

fuel prices;

competing airlines;

airport congestion;

unrelated schedule changes.

38. Limitation of Liability

Alliance agreements frequently contain clauses limiting liability.

Courts may need to examine:

whether the clause is valid;

whether it covers the particular loss;

whether gross negligence or intentional conduct is excluded;

whether mandatory law overrides the clause.

Consumer and passenger claims may also be subject to mandatory rules that cannot simply be excluded by contract.

39. Evidence in Alliance Disputes

Important evidence can include:

alliance agreement;

amendments;

schedules;

emails;

board minutes;

pricing documents;

revenue statements;

booking data;

code-share records;

passenger records;

internal communications;

termination notices.

Electronic evidence is particularly important because alliance relationships may operate through complex IT systems.

40. Burden of Proof

A claimant alleging breach should generally establish:

existence of the contract;

relevant contractual obligation;

breach;

causation;

loss;

entitlement to the remedy.

The exact burden and evidentiary rules depend on the applicable procedural and substantive law.

41. Difference Between Alliance Breach and Competition Infringement

These should not be confused.

Alliance breach

"You failed to perform your contractual obligation."

Competition infringement

"The agreement or conduct unlawfully restricts competition."

An agreement may therefore be:

valid between the parties but problematic under competition law;

commercially beneficial but unlawfully restrictive;

terminated without breach;

breached without involving competition law.

42. Liability Matrix

43. Most Important Legal Principles

Principle 1

An airline alliance is a collection of contractual relationships, not necessarily one single contract.

Principle 2

The court should examine the actual wording and scope of each agreement.

Principle 3

Termination of a joint venture does not necessarily terminate all alliance cooperation.

Principle 4

A codeshare and a broader alliance agreement are legally distinct arrangements.

The Lufthansa/SAS litigation is especially important for this principle. (Infocuria)

Principle 5

Alliance partners remain subject to EU competition law.

Principle 6

Extensive cooperation involving pricing, scheduling and network integration can create significant Article 101 concerns.

Principle 7

Passenger liability can attach to the operating carrier even where another airline sold the ticket.

The United Airlines judgment is particularly important here. (curia)

Principle 8

An alliance partner may have a contractual right of indemnity against another partner even where passenger-rights legislation imposes liability on the operating carrier.

44. Practical Example

Suppose Airline A and Airline B enter an alliance.

They agree:

A sells tickets;

B operates certain flights;

revenues are shared 50:50;

B provides 20 weekly connecting flights;

both airlines participate in a common frequent-flyer programme.

B suddenly removes 10 flights.

As a result:

A loses passengers;

customers miss connections;

passengers claim compensation;

A incurs additional rebooking expenses.

The litigation could involve four separate questions:

Question 1

Did B breach the alliance agreement?

Question 2

Does B owe contractual damages to A?

Question 3

Which airline owes passenger compensation?

Question 4

Does the alliance's capacity arrangement itself create competition-law concerns?

These questions may have different answers.

45. Key Case-Law Table

The first six are principally useful for the alliance/competition dimension, while the latter three are particularly useful for contractual allocation of responsibility and passenger claims.

46. Exam/Research Conclusion

Airline alliance agreement disputes in Europe are multi-layered disputes. They cannot be analysed solely as ordinary contract disputes because airline alliances combine contractual cooperation with EU competition law and mandatory passenger-protection rules.

The most important questions are:

What agreements actually exist between the airlines?

What is the governing law?

What contractual obligations were breached?

Was the alliance or one component lawfully terminated?

Was the arrangement a simple codeshare or a deeply integrated alliance?

Did the cooperation involve joint pricing or capacity coordination?

Which airline was the operating carrier?

Who bears passenger compensation?

Is there an indemnity between the alliance partners?

Does EU competition law restrict the contractual arrangement?

The Lufthansa/SAS litigation, particularly T-712/16, is especially significant because it demonstrates that European legal analysis must distinguish between a broad bilateral alliance, a joint venture and a codeshare rather than treating all cooperation as one arrangement. (Infocuria)

Ultra-short revision

Airline Alliance Dispute = Contract + Competition + Passenger Rights + Tort/Indemnity + Data/IP + Jurisdiction

Key words:
Alliance agreement → Code-share → Joint venture → Revenue sharing → Joint pricing → Schedule coordination → Termination → Good faith → Breach → Damages → Operating carrier → Regulation 261/2004 → Article 101 TFEU → Indemnity → Arbitration → Competition remedies.