Order 2024-10-7

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION
OFFICE OF THE SECRETARY
WASHINGTON, D.C.

Issued by the Department of Transportation

on the 15th day of October, 2024

Deutsche Lufthansa AG Docket DOT-OST-2024-0001

Violations of 49 U.S.C. §§ 40127, 41310, and

41712 Served October 15, 2024

CONSENT ORDER

This order concerns violations by Deutsche Lufthansa AG (Lufthansa) of the statutory

prohibition against discrimination in 49 U.S.C. §§ 40127 and 41310 and the statutory prohibition
against unfair practices in air transportation codified at 49 U.S.C. § 41712. The Department finds
that Lufthansa violated these statutes with respect to its treatment of 128 passengers on
Lufthansa flight 1334 from Frankfurt International Airport (FRA) to Budapest Ferihegy
International Airport, Hungary (BUD) on May 4, 2022.

On May 3, 2022, 131 passengers began a journey from New York City (JFK) to BUD to attend
an annual memorial event to honor an Orthodox rabbi. The passengers booked their tickets on
flights operated by Lufthansa, with a planned connection at FRA.

Based on the misconduct of some passengers on the initial Lufthansa flight from JFK to FRA
(Flight 401), Lufthansa prohibited 128 passengers from continuing on to BUD on their originally
ticketed flight (LH 1334) 1 delaying and disrupting their travel plans. This order directs
Lufthansa to cease and desist from future similar violations and assesses the carrier $4,000,000
in civil penalties.

1
Based on information submitted to the Department by Lufthansa, it appears that a passenger was permitted to
continue his travel and another passenger was permitted to continue travel as he was accompanying him. A third
passenger (religion unknown) was permitted to board the second flight to Budapest because the passenger’s second
flight was under a separate ticket from that used on Flight 401.
 Applicable Law

Pursuant to 49 U.S.C. § 41301, a foreign air carrier2 may provide foreign air transportation3 only
if the foreign air carrier holds a permit from the Department authorizing the foreign air
transportation or has a valid exemption from that section.4 A foreign air carrier that holds a
foreign air carrier permit from the Department is subject to the requirements of, among other
statutes, 49 U.S.C. §§ 40127, 41310, and 41712. Section 40127(a) prohibits a foreign air carrier
from subjecting a person in air transportation to discrimination on the basis of race, color,
national origin, religion, sex, or ancestry. Section 41310(a) prohibits a foreign air carrier from
subjecting a person in foreign air transportation to unreasonable discrimination. The Department
interprets the term “foreign air transportation” to include flight segments between two foreign
points, if the itinerary is to or from the United States with brief and incidental stopovers at a
foreign point without a break in the journey.5

Although a carrier may properly refuse to transport a passenger who presents a safety or security
risk under 49 U.S.C. § 44902, Federal law prohibits any carrier from refusing to transport a
passenger based on the passenger’s race, color, national origin, religion, ethnicity, or sex, and
subjecting a passenger to unreasonable discrimination on flights between the United States and
foreign points. Courts have found that any refusal of transportation by airlines must be rational
and reasonable and not capricious or arbitrary in view of the facts known to the airline at the
time.6

Section 41712 prohibits an air carrier, foreign air carrier, or a ticket agent from engaging in an
unfair or deceptive practice in air transportation or the sale of air transportation. In prior DOT
orders, OACP has found that discrimination based on a protected class is “unfair” within the
meaning of section 41712.7 In December 2020, the Department published in the Federal

2
49 U.S.C. § 40102(a)(21) defines a “foreign air carrier” as “a person, not a citizen of the United States,
undertaking by any means, directly or indirectly, to provide foreign air transportation.”
3
49 U.S.C. § 40102(a)(5) defines “air transportation” as “foreign air transportation, interstate air transportation, or
the transportation of mail by aircraft.” 49 U.S.C. § 40102(a)(23) defines “foreign air transportation” as “the
transportation of passengers or property by aircraft as a common carrier for compensation, or the transportation of
mail by aircraft, between a place in the United States and a place outside the United States when any part of the
transportation is by aircraft.”
4
The authority required by section 41301 is separate and distinct from the operations specifications and approvals
that such an entity must obtain from the Federal Aviation Administration (FAA) for operations to and from the
United States.
5
See Refunds and Other Consumer Protections, DOT Final Rule, 89 FR 32760, 32767-68 (April 26, 2024).
6
See Williams v. Trans World Airlines, 509 F. 2d 942 (2nd Cir. 1975).
7
See, e.g., DOT Order 2012-5-2 (The order notes that 49 U.S.C. § 41712 has been interpreted to prohibit carriers
from discrimination on the basis of race, color, national origin, religion, sex, or ancestry.)

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Register a final rule titled “Defining Unfair or Deceptive Practices.”8 That rule defined the terms
“unfair” and “deceptive” for purposes of Section 41712. Pursuant to the rule, a practice is
“unfair” to consumers within the meaning of Section 41712 if: 1) it causes substantial harm to
consumers; 2) the harm is not reasonably avoidable; and 3) the harm is not outweighed by
benefits to consumers or competition.9 Proof of intent is not necessary to establish unfairness.10
In August 2022, DOT issued a guidance document to inform the public and regulated entities
about DOT's interpretation of the terms “unfair,” “deceptive,” and “practices” as it relates to its
statutory authority to prohibit unfair or deceptive practices.11 In that document, DOT explained
that “[a]s a public policy matter, the Department has found that discriminatory conduct in and of
itself constitutes an unfair practice.”

Pursuant to 49 U.S.C. § 46301, prior to January 2023, violation of sections 40127, 41310, and
41712 may subject an airline to civil penalties of up to $37, 377 for each violation.12

Facts and Conclusions

Lufthansa is a foreign air carrier that holds a foreign air carrier permit and operates flights to and
from the United States using at least one aircraft having a designed capacity of more than 30
passenger seats. One condition of Lufthansa’s foreign air carrier permit is that Lufthansa must
“comply with such other reasonable terms, conditions, and limitations required by the public
interest as may be prescribed by the Department, with all applicable orders or regulations of
other U.S. agencies and courts, and with all applicable laws of the United States.”13 Accordingly,
Lufthansa is legally subject to the requirements in 49 U.S.C. §§ 40127, 41310, and 41712.

Facts about the flight

On May 3, 2022, 131 passengers flew on Lufthansa Flight 401 from JFK to FRA, with a final
destination of BUD.

Despite the 131 passengers having a common destination, most of the passengers did not know
each other and did not book their flights as a single group. Rather, many of the passengers
purchased their tickets as individuals, or in small groups. In addition, while some passengers
booked their tickets using frequent flyer miles, or on Lufthansa’s website, many of the
passengers booked their flights through specific travel agents who specialize in arranging travel

8
85 Fed. Reg. 78707 (December 7, 2020).
9
14 CFR 399.79(b)(1). Pursuant to 14 CFR 399.79(e)(2), “when a regulation issued under the authority of section
41712 does not apply to the practice at issue, then the Department shall articulate in the order the basis for concluding
that the practice is unfair or deceptive to consumers as defined in this section.”
10
14 CFR 399.79(c).
11
87 Fed. Reg. 52677 (August 29, 2022).
12
87 Fed. Reg. 15839.
13
See https://www.regulations.gov/document/DOT-OST-2007-0030-0003.

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of this type. Those travel agents generally purchase a block of seats in advance from Lufthansa
and then alert Lufthansa of the names of the passengers who booked those seats. While a
substantial majority of the passengers booked their tickets through two travel agencies, each
travel agency had booked the passengers under multiple reservation numbers.

A significant majority of the 128 passengers were male. Most wore the distinctive garb typically
worn by Orthodox Jewish men (black hats, black jackets, white shirts, black pants, and black
dress shoes). The passengers on Flight 401 to FRA who were interviewed by OACP identified
themselves as Jewish, and some reported that Lufthansa flight attendants informed them about
the requirement to wear a face mask during the flight and to not assemble in the aisles, galleys
and emergency exits.14 The passengers also stated that they did not observe any passengers
failing to comply with crew member instructions.

Although the Lufthansa crewmembers onboard Flight 401 did not identify any specific
passengers who failed to comply with crewmember instructions to wear face masks or to return
to their seats, the Captain of Flight 401 alerted a Lufthansa Security Duty Manager (SDM) about
the misbehavior of passengers onboard the flight and informed the SDM that the passengers were
connecting to another flight to BUD based on one or more of the Jewish passengers informing a
flight attendant about their destination. As a result, the SDM placed a High Priority Comment
(HPC) on the itineraries of all passengers that the SDM identified as connecting on Flight 1334
to BUD and who were booked and checked in as groups (i.e., two or more passengers traveling
together). This resulted in 12315 passengers’ itineraries being flagged with an HPC. Every one of
the passengers with an HPC was Jewish.

The HPC, which is a feature of Lufthansa’s internal booking system, prevents a passenger from
boarding a flight until a gate agent acknowledges reading the comment. The HPC applicable to
the passengers connecting from LH 401 to LH 1334 instructed the gate agent in FRA to contact
the flight manager about a group of passengers. OACP’s investigation revealed that Lufthansa
ground staff handling LH 1334 observed the HPC on the passengers’ itineraries and alerted the
Captain of that flight. The Captain of LH 1334 called the Security Desk directly. The Security
Desk told the Captain that a “group” on LH 401 had caused significant problems onboard LH
Flight 401 by not following crew requests to comply with regulations. The Security Desk did not
provide details about the specific individuals or seats. A Lufthansa report recognized that
approximately 120 passengers were traveling to Budapest and surmised that the airline’s refusal
to transport the entire group could also mean a blanket exclusion of bystanders who behaved

14
The Act on the Prevention and Control of Infectious Diseases in Humans (Infection Protection Act—IfSG)
provided, in relevant part, that “air transport . . . may only be used by passengers or airline staff . . . if these persons
wear a respiratory protection mask (FFP2 or comparable) or a medical face mask (mouth-nose protection) during
transport.” Lufthansa’s Conditions of Carriage in effect at the time of the flight stated that passengers “are required
to wear a face mask which entirely covers mouth and nose during boarding, throughout the flight and when leaving
the aircraft.” In addition, U.S. and German law prohibited (and continue to prohibit) passengers from assembling in
the aisles, galley area and emergency exits during flight.

15
While 123 passengers received an HPC in their reservation, an additional 7 passengers were not boarded on Flight
1334 for reasons that are not known to Lufthansa.

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peacefully and were compliant with the applicable laws onboard Flight 401. Lufthansa
acknowledged that the crew of LH 1334 did not have personal knowledge of the situation, and at
that time Lufthansa concluded that it was not practical to address each passenger individually. As
a result, Lufthansa prohibited 128 passengers from continuing on to BUD as planned.

On the ground at FRA, Lufthansa staff did not conduct a conventional boarding process for the
LH 1334 flight. Instead, the Integrated Operations Control Center (“IOCC”), a group of
Lufthansa’s ground operations management personnel stationed in Frankfurt Airport, made the
decision to board only those passengers who did not have an HPC affixed to their itineraries in
the electronic reservation system. None of the IOCC staff members had any interaction with the
passengers of LH 401 or LH 1334, as their decision was based entirely upon information from
the SDM, who also had no interaction with the passengers, and the HPC notations in the
reservation system. Accordingly, the alternative boarding procedure was implemented by the
gate staff, as they called to the gate by name those passengers without an HPC notation. The
remaining passengers waited in the gate area, confused and upset. LH 1334 then departed
without them. Lufthansa rebooked the majority of the passengers who were denied boarding on
LH 1334 on other Lufthansa Group flights on the same day, and some passengers made their
own arrangements to travel to Budapest or surrounding cities on other airlines.

Most passengers who were interviewed by OACP stated that Lufthansa treated them all as if they
were a single group, and denied boarding onto LH1334 to BUD to everyone for the apparent
misbehavior of a few, because they were openly and visibly Jewish.

Legal conclusions

By operating a flight from the United States to Budapest, with an incidental stopover in
Frankfurt, Lufthansa engaged in foreign air transportation and is therefore subject to sections
40127 (prohibiting foreign air carriers from subjecting a person in air transportation to
discrimination on the basis of race, color, national origin, religion, sex, or ancestry), 41310(a)
(prohibiting a foreign air carrier from subjecting a person in foreign air transportation to
unreasonable discrimination), and 41712 (prohibiting unfair or deceptive practices in air
transportation). The 128 passengers in this matter held tickets for, and expected to engage in, a
continuous journey from New York to Budapest, with an expected short layover in Frankfurt of
mere hours. While this is sufficient to find that jurisdiction attaches, we also find that the chain
of events leading to the passengers’ denied boarding all took place on the flight from New York
to Frankfurt, or in Frankfurt itself, immediately upon the passengers’ disembarking. The denial
of transport in Frankfurt was a continuation of a pattern of discriminatory behavior that began on
a flight that originated in the United States.

Lufthansa’s decision to affix an HPC to the reservations of nearly every passenger traveling in a
group to Budapest without limiting such affixation to those passengers who Lufthansa verified
failed to follow crew instructions on LH 401, which did not comport with Lufthansa’s own
boarding procedures, directly resulted in the inability of the passengers to travel on the flights
they purchased. As such, Lufthansa took action that had an adverse effect on these passengers
whose only affiliation with each other was that they were of the same religion and/or ethnicity.
Lufthansa’s actions impacted passengers who did not engage in problematic conduct. OACP

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finds that, under the totality of the circumstances, Lufthansa’s treatment of the 128 Jewish
passengers as a collective group, based on the alleged misconduct of a smaller number of those
individuals, constitutes discrimination based on religion in violation of 49 U.S.C. § 40127.

Based on our review of available evidence, we find that Lufthansa’s staff made no meaningful
effort to specifically identify and track the individuals who failed to follow crew instructions to
abide by the applicable laws and regulations, and to tailor the consequences accordingly. Those
efforts could have included obtaining the names and likenesses of the misbehaving passengers
and linking them to the seats they were sitting in. To the extent that misbehaving passengers
were out of their seats, Lufthansa staff could have tracked which seats were empty and then
identified which passengers took those seats. While these processes may not have been perfect,
they would have resulted in tracking the individuals about whom Lufthansa had concerns and
would have significantly reduced the likelihood that innocent passengers would be denied
boarding for discriminatory reasons. Instead, Lufthansa has failed to show that its crew took any
action to document the identities of specific passengers who engaged in misconduct.

We recognize that the SDM who placed the HPC on the passengers’ itinerary, as well as the
other staff members of the IOCC were not onboard the flight and never saw or came into contact
with any of the passengers. However, it is also undisputed that the flight crew of Flight 401
alerted the SDM about the “misbehavior” of passengers onboard the flight and informed the
SDM that the passengers were connecting to another flight to BUD. Given the totality of the
circumstances, this does not alter our conclusion that Lufthansa behaved in a discriminatory
manner.

OACP also finds that because Lufthansa discriminated against passengers on the basis of
religion, as set forth above, Lufthansa also subjected these passengers to “unreasonable
discrimination” in violation of 49 U.S.C. § 41310.

For the reasons set forth below, OACP finds that Lufthansa’s practice of preventing the 128
passengers from continuing on their connecting flight based on the conduct of a smaller number
of similarly situated passengers is “unfair” in violation of 49 U.S.C. § 41712. First, the practice
imposed substantial harm. Lufthansa’s passengers were unable to use the service that they paid
for, while being forced to incur delay to complete their journey, which caused considerable stress
on the affected passengers. Second, the harm was not reasonably avoidable, as a number of
Lufthansa passengers on inbound Flight 401 were denied boarding for conduct that they did not
commit. Third, the harm is not outweighed by countervailing benefits to consumers or
competition.

Lufthansa Response

Lufthansa states that it is a major international airline that operates to more than 100 countries
and each year welcomes millions of passengers of all religions and ethnicities aboard its aircraft.
The carrier also states that as an airline group proud of its mission to connect people, cultures,
and economies, its goal is to be a bridge builder. Lufthansa states that it has zero tolerance for
any form of religious or ethnic-based discrimination, including antisemitism. Lufthansa states

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that it and the entire passenger airline group have had a robust and fruitful relationship with the
Jewish communities around the world, especially in the United States. Lufthansa states that it is a
trusted choice, to this day, for members of the Orthodox Jewish Community who continue to use
the Lufthansa Group for travel throughout Europe as well as to Israel.

Lufthansa states that it regrets and has publicly apologized on numerous occasions for the
circumstances surrounding the decision to deny boarding to the affected passengers from LH
1334. Lufthansa, however, denies any suggestion that any of its employees engaged in any form
of discrimination. Moreover, Lufthansa strongly disputes that the Department has legal authority
to enforce 49 U.S.C. § 41712, 49 U.S.C. § 40127 and 49 U.S.C. § 41310 on an extraterritorial
basis with respect to events that occurred in FRA within the territory of the Federal Republic of
Germany.

Lufthansa notes that the denied boarding incident at FRA resulted from an unfortunate series of
inaccurate communications, misinterpretations, and misjudgments throughout the
decision-making process. Lufthansa maintains that these actions, although regrettable, do not
support any finding of discrimination and the Department’s findings in this case. Lufthansa
states that the decision to deny boarding onto the BUD flight was based solely on the reports
concerning the non-compliant actions of numerous passengers on LH 401 to FRA. According to
the carrier, the decision was made solely on the basis of safety and security concerns by
Lufthansa airport management personnel located in an airport operational control center, the
IOCC, none of whom ever saw or came into contact with any of the passengers, and without
awareness of the passengers’ ethnicity or religion. Lufthansa states that these employees made
decisions based solely on objective criteria and information contained in Lufthansa’s electronic
reservation management system, not based on the perceived religion or ethnicity of any of the
passengers.

Lufthansa states that the safety and security of flight operations is Lufthansa’s highest priority.
Lufthansa asserts that a large number of the passengers on LH 401, who were denied boarding at
FRA, repeatedly disregarded crew instructions to wear face masks, which at the time was
mandated under German law due to the COVID-19 public health emergency. Lufthansa states
that, in addition, passengers were requested to avoid gathering in the aisles, galleys, and near
emergency exit doors, as required under safety and security regulations under U.S. and German
law. Lufthansa steadfastly maintains that the actions of the crew of LH 401 were taken in the
interest of safety and security. Lufthansa states that the crew of LH 401 did not discriminate
against any passenger on the basis of perceived religion or ethnicity or manifest any intentional
malice or ill intent toward any passenger. Lufthansa notes that certain flight attendants on LH
401 permitted and facilitated praying by small gatherings of passengers during the flight, which
the carrier asserts underscores the Lufthansa crew’s lack of any discriminatory feelings or
actions toward any of the passengers. Lufthansa states that a large number of passengers (as
many as 60 passengers at any given time during the flight) repeatedly disregarded both in-flight
public address announcements from the flight deck and in-person crew instructions. Lufthansa
stresses that in some cases, passengers not only refused to comply with safety and security
requirements, but argued with Lufthansa flight attendants and other passengers who courteously
reminded them of the obligation to wear masks. The conduct of those passengers, according to
Lufthansa, placed the crew and other passengers of LH 401 in a difficult situation. The passenger

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misconduct on LH 401, Lufthansa states, also obstructed flight attendants in the Economy Class
cabin from providing food and beverage service and inconvenienced other passengers. Lufthansa
concludes that the LH 401 flight crew was diligent and professional in addressing this situation.

Lufthansa states that the Captain of Flight LH 401 made three separate special announcements
over the public address system during the flight after the flight attendants informed him of the
problems that they were experiencing. According to Lufthansa, the Captain instructed the
passengers to properly wear their masks during flight, to not congregate or block the aisles, and
to not gather in galleys or block emergency exits. Lufthansa also states that, when making these
announcements, the Captain advised the passengers that a potential consequence for failing to
adhere to the rules and follow crewmember instructions could be the possible exclusion from
future transportation, including not being permitted to board a connecting flight.

Lufthansa further states that the crew of LH 401 was unable to identify the specific passengers
who engaged in misconduct on the flight because, according to Lufthansa, the infractions were
so numerous, the misconduct continued for substantial portions of the flight and at different
intervals and the passengers changed seats during the flight. Lufthansa disagrees with the
Department’s position that the crew could have reasonably identified the passengers at issue.
Lufthansa states that the large number of non-compliant passengers and the fact that many traded
seats made it impossible to identify them. In such circumstances, Lufthansa maintains that the
crew appropriately prioritized addressing the large-scale passenger misconduct, which
jeopardized the safety and security of the flight and obstructed the crew from performing their
safety and passenger service duties, rather than attempting to develop a list of individual
passengers who were violating regulations.

Lufthansa rejects any allegation by the Department that the events in this matter resulted from
any form of discrimination and disputes that any employee involved in the decision at FRA to
deny boarding manifested bias against the impacted passengers on the basis of the passenger’s
perceived religion or ethnicity, conduct that is strictly prohibited at Lufthansa. Lufthansa states
that, although there had been errors in company procedure and communications, it did not
conclude that Lufthansa or its employees discriminated on the basis of perceived religion or
ethnicity.

Lufthansa states that it is proud of its role in connecting people, cultures, and communities across
the globe, and has zero tolerance for any form of religious or ethnic-based discrimination. The
carrier states that following the events of May 4, 2022, Lufthansa enhanced its support of
international efforts to combat antisemitism in close cooperation with the Jewish community as
well as engaged with the German Federal Government’s Commissioner for Jewish Life in
Germany and the Fight Against Antisemitism. Lufthansa states that it is the first airline to adopt
the principles of the International Holocaust Remembrance Alliance (IHRA), including the
IHRA’s definition of antisemitism. The carrier also states that, more recently, it has taken a
leading role with other German companies in the “Never Again is Now” campaign in Germany
which supports Germany’s Jewish community. Lufthansa states that it has also implemented an
employee training program developed in partnership with the American Jewish Committee
covering the IHRA principles to combat racist, xenophobic, and antisemitic behavior. Lufthansa
adds that it has implemented changes to its procedures and policies and provided additional

8
employee training to minimize the likelihood of a reoccurrence. Finally, Lufthansa notes that the
Executive Board of Lufthansa appointed a Human Rights Officer, a new senior leadership
position of Vice President Human Rights and Discrimination-Prevention, with responsibility for
overseeing Lufthansa’s efforts to prevent all forms of discrimination, particularly antisemitism.

Lufthansa is entering into this Consent Order to avoid litigation threatened by the Department,
despite Lufthansa’s belief that the Department lacks jurisdiction over events that occurred
outside the United States, and despite disagreeing with the Department’s conclusions.

Decision

OACP views seriously Lufthansa’s violations of Sections 40127, 41310, and 41712.
Accordingly, after carefully considering all the facts in this case, OACP believes that
enforcement action is warranted. In order to avoid litigation, and without admitting the
violations alleged above, Lufthansa consents to the issuance of this order to cease and desist
from future similar violations of 49 U.S.C. §§ 40127, 41310, and 41712, and to the assessment of
$4,000,000 in compromise of potential civil penalties. This assessment is appropriate considering
the nature and extent of the violations described herein, serves the public interest, and establishes
a strong deterrent to future similar unlawful practices by Lufthansa and other carriers.

This order is issued under the authority contained in 49 CFR Part 1.

ACCORDINGLY,

1. Based on the above discussion, we approve this settlement and the provisions of this
order as being in the public interest;

2. We find that in May 2022, Deutsche Lufthansa AG took actions that effectively
prohibited 128 Jewish passengers, members of a visible and discrete religious minority,
from completing their itinerary from New York City to Budapest as planned, based on
the misbehavior of some of those passengers on the first segment of their journey (LH
401 from JFK to FRA);

3. We find that by engaging in the conduct described in paragraph 2, above, Deutsche

Lufthansa AG discriminated on the basis of religion in violation of 49 U.S.C. § 40127;

4. We find that by engaging in the conduct described in paragraph 2, above, Deutsche

Lufthansa AG committed unreasonable discrimination in violation of 49 U.S.C. § 41310;

5. We find that by engaging in the conduct described in paragraph 2, above, Deutsche

Lufthansa AG committed an unfair practice in violation of 49 U.S.C. § 41712;

6. We order Deutsche Lufthansa AG and its successors and assigns to cease and desist from
further violations of 49 U.S.C. §§ 40127, 41310, and 41712;

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 7. We assess Deutsche Lufthansa AG $4,000,000 in civil penalties that might otherwise be
assessed for the violations described in paragraphs 2-5 above; Of this total amount,
$2,000,000 shall be due and payable within 30 days of the issuance date of this order.
The remaining $2,000,000 is being credited for compensation Lufthansa paid to affected
passengers in this matter beyond that which is required by law; and

8. We order Deutsche Lufthansa AG to pay within 30 days of the issuance of this order the
penalty assessed in Ordering Paragraph 7. Payment shall be made through Pay.gov to the
account of the U.S. Treasury in accordance with the instructions contained in the
Attachment to this order. Failure to pay the penalty as ordered shall subject Deutsche
Lufthansa AG to the assessment of interest, penalty, and collection charges under the
Debt Collection Act and to further enforcement action for failing to comply with this
order.

This order will become a final order of the Department 10 days after its service date unless a
timely petition for review is filed or the Department takes review on its own motion.

BY:

BLANE A. WORKIE
Assistant General Counsel
Office of Aviation Consumer Protection

An electronic version of this document is available at

www.regulations.gov

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