Name: Mr. Simon Paul Cordell
Address: 109 Burncroft Avenue, Enfield, London, EN3 7JQ
Email: Re_wired@ymail.com
Tel: +447864217519
Date: 18/06/2025
Trip Air Ticketing (UK) Limited Floor 10, 70 St Mary Axe London, England
EC3A 8BE
Subject:
Response to Legal Correspondence – Jurisdiction, Procedural Conduct &
Litigant Rights
Dear Trip Air Ticketing (UK) Limited,
This letter serves not only as a response to your recent communications
concerning “Booking No. 1653702646294295”
(Case No. 46906014), but also as a firm assertion of
my legal standing as a self-represented party.
I must also apologise for the slight delay in response. I have devoted extensive time to preparing this case, which unfortunately meant I had to momentarily prioritise essential personal matters, which eventfully caught me up, such as securing new transport to attend courts and also attending to domestic affairs, so that I can present my case securely and competently in a legal setting.
My position as a litigant in person is not a reflection of preference, but necessity and it is grounded in legitimate and recognised legal precedent. I am fully aware of my rights under “Rule 46.5 Of The Civil Procedure Rules (CPR),” which entitles litigants to recover reasonable costs for work carried out on their own behalf. This is not speculative, nor is it a theoretical position; I view this case as a practical and meaningful opportunity to exercise and validate that entitlement under established UK law. While I would have preferred to be in a financial position to instruct legal representation, that option is currently beyond my means. As a result, I have had to dedicate substantial time and effort, time taken directly from my personal and professional life, to engage with these legal proceedings. This is time for which any solicitor, had I been able to instruct one, would have charged fees as a matter of course, despite not being personally affected by the outcome. The fact that I am both the claimant and the one bearing this burden makes the imbalance all the more unjust. This situation has compelled me to deepen my understanding of the legal framework surrounding liability, acceptance, and the recovery of legal expenses, particularly in cases where a litigant in person is entitled to seek compensation for their work under “Rule 46.5 of the Civil Procedure Rules (CPR).” I approach this case with seriousness, precision, and due care, not only because of its direct impact on me, but also because it forms part of a broader legal journey. I am currently involved in other proceedings, including one where a significant “Abuse Of Process” has occurred, and these experiences are actively shaping my legal knowledge and approach, whether acting as a litigant or otherwise. Through this process, I have reaffirmed the validity of my rights as both a consumer and a claimant. I remain confident that I am legally and factually justified in the dispute over my booking, and I fully expect this matter to be resolved in accordance with statutory protections and the principles of procedural fairness. I therefore request compensation for the recovery of my “Legal Expenses” to be established as compensated.
I acknowledge receipt of your latest messages: one from Joy of the Customer
Success Team, dated “Tuesday 27 May 2025 At 08:21 BST,”
and the prior from Magali, Legal Counsel, also dated “Tuesday
27 May 2025 At 08:21 BST.” This letter serves as my formal reply
to both!
Following a review of Trip.com’s Updated Terms and Conditions (as of 27 May 2025), alongside Companies House data and relevant UK legislation, I have identified “Jurisdictional Inconsistencies, Procedural Irregularities, And Multiple Breaches Of Consumer Protection Obligations.” These issues warrant immediate attention and rectification.
1.
Jurisdiction Argument – UK Law Supersedes Singapore Enforcement:
Trip.com’s assertion that disputes
must be “Resolved
Exclusively In Singapore” conflicts with multiple legal principles “Governing
Consumer Rights In The UK.”
Hague Convention on Choice of
Court Agreements (2005) – Consumer Contracts Are Excluded
Under “Article 2(1)(a)” of the “Hague Convention,” consumer contracts “Do Not Fall Under Mandatory
Jurisdiction Clauses.” This exclusion means “Trip.Com Cannot Legally Enforce Singapore Jurisdiction”
if the transaction
qualifies as a “Consumer
Purchase,”
which it does.
UK Legal Framework – CJJA 1982
(Civil Jurisdiction and Judgments Act)
·
Section
15B(2):
ensures that “UK-Based Consumers Retain The Right To Sue Overseas
Entities In UK Courts,” even if the company is
incorporated abroad.
·
Section
15B(3):
prevents companies from “Suing
UK Consumers Outside The UK,” unless strict legal conditions apply, which are “Absent”
in this case.
·
Section
15B(6):
makes it “Impossible
To Contractually Restrict Consumer Rights” unless such clauses “Expand Legal Options Rather
Than Limit Them,”
Trip.com’s terms do the opposite.
By claiming that Singapore
jurisdiction overrides UK consumer protections, Trip.com “Misrepresents The Legal
Position Entirely.”
The company’s “Active
UK Registration Establishes Statutory Obligations,” rendering the jurisdiction argument “Invalid.”
2.
Trip.com’s UK Entity – Confirmation of Legal Responsibility:
Despite the claim that operations fall
under “Trip.Com Travel Singapore Pte. Ltd., Trip Air
Ticketing (UK) Limited Remains An Officially Registered UK Entity,” confirmed
via “Companies House.”
a.
Trip Air Ticketing (Uk) Limited
Matching
Previous Names:
Ctrip Air Ticketing (Uk) Limited
10811048
- Incorporated on 9 June 2017
Floor 10 70 St Mary Axe,
London, England, EC3A 8BE.
b. Trip Air Ticketing (Uk) Limited
Total
number of appointments 1
Floor 10, 70 St Mary Axe,
London, England, EC3A 8BE.
·
Trip.com Terms and Conditions: Furthermore, “Trip.com’s own Terms and Conditions
(May 27, 2025)” (https://uk.trip.com/contents/service-guideline/terms.html?locale=en-GB) state that “Both Trip.Com Travel
Singapore Pte. Ltd. And Trip Air Ticketing (UK) Limited Operate The Platform,”
using “And”
or "We, Our, Us," thus consolidating both companies
under a “Shared
Operational Identity,” reinforcing Trip.com’s Liability due
to “UK-based operations.”
·
Trip Air Ticketing (UK) Limited Company
Information: This Companies House listing confirms that “Trip Air Ticketing (Uk) Limited” is an “Active UK-Registered Company,” further supporting my jurisdiction argument. https://find-and-update.company-information.service.gov.uk/company/10811048.
Or
Yet:
a.
“Only
The Singapore Address (30 Raffles Place, #29-01, Singapore 048622) Is
Explicitly Listed,”
while “Trip
Air Ticketing (UK) Limited’s UK-Registered Address Is Omitted.”
b.
“Despite
This Omission, UK Jurisdiction Applies,” as “Trip
Air Ticketing (UK) Limited Is Legally Accountable” under “UK Law And Consumer
Protection Regulations.”
c.
Attempting
to sidestep legal responsibility by misrepresenting the UK entity’s direct
consumer obligations “Will
Not Hold Up Under Scrutiny.”
3.
Civil Restraint Order Threat – Direct Contradiction in Jurisdiction Argument:
The Correspondence Signed By Magali
German, EMEA Legal Counsel, states:
a.
“Should proceedings be issued: > - We will
seek strike-out under “CPR
3.4”
(no reasonable grounds).
b.
We will seek to recover legal costs under “CPR 44” due to unreasonable conduct.
c.
The court may also consider “Civil Restraint Orders” should this pattern of litigation
persist.”
This statement “Directly Contradicts Trip.com’s
Previous Claim That UK Jurisdiction Does Not Apply.”
·
Contradiction
and Jurisdictional Recognition
a.
A
“Civil
Restraint Order (CRO) Must Be Filed In UK Courts.”
b. “If Trip.Com Wishes To
Enforce A Restraint Order, It Must Engage With UK Jurisdiction,” which “Invalidates Its Singapore Jurisdiction
Argument Entirely.”
c. “CJJA 1982, Section 15b(6)” prohibits enforcement of overseas
jurisdiction clauses that “Strip
UK Consumers Of Their Local Rights,” meaning Trip.com “Cannot Selectively Apply UK Law Only When Convenient.”
d. By “Threatening To File A Civil Restraint Order,” Trip.com “Admits That UK Courts Govern
Disputes Related To Its UK Entity” while simultaneously “Denying UK Jurisdiction Exists.” This contradiction “Collapses Any Attempt To
Dismiss Legal Accountability Under UK Consumer Law.”
4.
Consumer Protections – UK Legal Safeguards Apply
·
Trip
Air Ticketing (UK) Limited remains bound by “The Consumer Rights Act 2015,” ensuring “Transparent Business
Practices And Contract Fairness”:
a.
Section
9:
Goods and services must be “Of
Satisfactory Quality.”
b.
Section 11: Goods and services must be “As Described.”
c.
Sections
19-24:
Consumers retain the right to “Reject, Request Repair, Or Receive Compensation.”
Additionally:
5. Required
Action – Legal Position & Next Steps
·
Given
these findings, the following actions must be taken:
a. “Formal Confirmation That Trip
Air Ticketing (UK) Limited Acknowledges UK Jurisdiction” for consumer disputes, in line with
CJJA 1982.
b. “Corrections To Misleading
Contractual Statements Within Trip.com’s Terms And Conditions,” ensuring full transparency regarding
UK legal obligations.
c. “Resolution Of [Response to
Legal Correspondence – Jurisdiction Accountability, Consumer Protections, and
Misuse of Procedural Threats] In Compliance With UK Consumer Protection
Statutes,”
rather than procedural avoidance tactics.
·
Failure
to comply within “14
Days”
will necessitate “Formal
Escalation”
through “UK Regulatory
Bodies,” including:
a.
Competition
and Markets Authority (CMA): Consumer
protection enforcement.
b.
Civil
Aviation Authority (CAA): Regulatory
oversight on travel industry practices.
c.
Financial
Ombudsman Service:
Investigation into
contractual fairness and financial compensation compliance.
6. Final
Legal Position, Absolute Jurisdiction
Accountability
·
Trip.com
“Cannot
Legally Enforce Singapore Jurisdiction Against A UK Consumer,” because:
a. “Trip Air Ticketing (UK) Limited
Is A UK-Registered Company,” governed by “UK Consumer Protection Laws.”
b. “UK Law (CJJA 1982 & Consumer
Rights Act 2015) Supersedes Restrictive Jurisdiction Clauses,” making enforcement under Singapore
law “Unenforceable
In England.”
c. “Trip.com’s Procedural
Threats Rely On UK Legal Mechanisms,” proving “Its
Own Recognition Of UK Jurisdiction,” contradicting previous statements.
·
A
written response is expected within “14 Days,” confirming “Jurisdiction Acknowledgment And Corrective Actions.”
7. Misleading Booking Interface & Retroactive
Platform Changes
·
As part of this claim, I wish to draw
attention to documented evidence that directly challenges several assertions
made by regarding
the functionality of its booking system. maintains that “the system operated correctly at all
times,” that I “failed to add baggage for the return
segment,” and that “the platform
clearly prompts users to add baggage per flight segment.”
·
This is incorrect and misleading. I have
captured “Screen Recordings And Screenshots”
from my account
which show that, at the time of booking, the site displayed “Multiple
Baggage Allowance Sections,” both labelled in similar terms, some
appearing as paid options, others as free, with “No
Clear Indication” that
only a single segment was being covered. Based on the layout and presentation
of these entries, I reasonably believed that “Both
Outbound And Return Flights Included 15 Kg Of Baggage,”
consistent with my booking intent.
·
The platform’s labelling and structure at that
time did “Not” warn me that
baggage had to be separately added for the return journey. The interface “Did
Not Explain” which
segment was covered, nor did it clearly distinguish between paid and
complimentary options. This ambiguity directly contributed to the confusion and
the unexpected changes that followed.
·
Crucially, since I submitted my complaint, the website has “Undergone Visible Changes.” The
interface has been redesigned to “Eliminate Or
Consolidate” the previous distinctions I
encountered, suggesting that the original layout was flawed or inadequate. The “Paid-For
Baggage Section” that appeared when I first
reviewed my booking is no longer visible in its original form. These changes
were implemented “After”
my claim was raised, which raises serious concerns about transparency and
accountability.
·
The implication is clear: the interface was
sufficiently misleading at the time of booking to cause “Real
Financial Loss,” and Trip.com’s post-complaint modifications
demonstrate an implicit recognition that the presentation may have contributed
to user error. To now assert that I alone am responsible for misunderstanding
the process, when the design itself was a likely source of confusion, is unjust
and unsubstantiated.
·
This section of my claim is supported by
timestamped screenshots and video walkthrough evidence. These materials confirm
that my belief regarding return baggage coverage was “Not
Only Reasonable,” but directly informed by the way Trip.com’s
system appeared and operated at the time.
§ Weblink: 35. was the 26th-Sent-Soon.mp4
§ Exhibit: 35. was the 25th-Sent-Soon video transcribe.docx
8.
Offers Of Compensation Offered By Trip.Com:
· I stay truly negotiable in these legal proceedings and I therefore I appreciate Trip.com’s willingness to offer partial reimbursement and goodwill credit. Specifically, I acknowledge the updated confirmation of compensation for “Baggage Fees Paid At London Gatwick (£40.00) And Antalya Airport (£69.63),” totaling “£109.63.” I accept this refund “without prejudice” as a partial settlement only.
· However, to be absolutely clear, these amounts represent “Financial Losses I Should Never Have Incurred,” caused directly by systemic or transactional failings on the part of . As such, this reimbursement is not a discretionary offer, it is a “Basic Obligation Of Restitution.” The responsibility to return money taken in error is not contingent on the outcome of wider proceedings. In your role as loss adjusters and facilitators, this element of the claim should be processed “Without Delay Or Condition.”
· I also wish to make it clear that my broader pursuit of compensation is not rooted in inflexibility, but in the “Fair And Lawful Application Of UK Consumer And Civil Procedure Standards.” Acting as a self-represented party in this matter has required me to invest “Substantial Time, Research, And Personal Resources,” work that, if carried out by an instructed solicitor, would have attracted “Billable Costs Recoverable Through The Courts.” I have met the same evidentiary and procedural expectations yet remain uncompensated for the role I’ve played in navigating this dispute diligently and in accordance with law.
· It Is Precisely Because Of This Imbalance That I Seek Recovery of:
a.
“All Out-Of-Pocket Losses Directly
Caused By The Service Failure.”
b.
“Reasonable Legal Preparation Costs,”
as permitted under “Rule 46.5 of the Civil Procedure Rules
(CPR)”
c.
“Appropriate Compensation”
for disruption, distress, and ongoing personal impact.
·
Trip.com’s Customer Success Team Asked:
“Would
you please let us know if you accept the proposed offer? Kindly note that
acceptance will be considered the full and final settlement of this case.”
Respectfully, I cannot accept the offer as it stands, because it fails to
acknowledge the full scope of my claim, my proven entitlement to reimbursement,
and the legal protections afforded to me as a UK consumer and claimant.
· I remain willing to resolve the matter constructively, but only through a settlement that reflects the full extent of financial and procedural harm experienced in this case.
9.
Trip.com’s Solicitor Engaging in Procedural Evasion –
Failure to Address Key Evidence:
·
Failure
to Trust and Acknowledge the Correct Information from the Start: From the very beginning of this claim,
dated “12th January 2025,” Trip.com’s representatives failed to
accurately engage with the facts presented. Despite “Clear Explanations Provided,” the company named as Trip.com,
employees have failed to understand the claim in hand.
10. Key Incidents:
|
Nub |
Key Incidents |
|
1. |
Trip.com’s customer service employees have
consistently avoided acknowledging my main claim letter. They initially
responded to my “First Email,” confirming that they would wait
for my complete claim letter detailing my issues. However, after I prepared
and sent the claim, they ceased all communication, failing to reply from the
same email. This lack of response started from the start of legal proceedings
and further prompted me to seek alternative methods to contact Trip.com’s
staff to address my concerns, within emails “1 to 5.” 01st-Sent: From Me
(Simon Cordell) to Trip.com, EasyJet, and SunExpress |
|
2. |
02nd-Received (1 of 3): This was an automated reply from EasyJet. 02nd-Received (2 of 3): I received a mailer daemon failure
notice from (SunExpress as it rejected the email) 02nd-Received (3 of 3): “I Received A Response From Trip.Com
Customer Service Team!” |
|
3. |
03rd-Sent: I follow-up and request for resolute caseworker
regarding my complaint! |
|
4. |
04th-Sent: I continued to follow up on previous correspondence. |
|
5. |
05. 5th Received: I received an advertisement from trip.com,
rather than a response to my claim! |
|
6. |
I had to remain persistent and explore alternative
methods to submit my claim, which led to a telephone call on the “06th
of April 25.” During this call, I discussed my concerns. I have Exhibited
the “MP3 Recording” of our correspondence dated “02nd
of April 2025,” already. The customer service representative provided me with
a weblink via an email that is titled as the “07. 07th-Received”
and this was to be able to submit my claim; however, that link did not
function correctly. Consequently, I had to reach out again to Trip.com, as
evidenced by the attached correspondence. 06th-Made: Phone Call to Trip.com (No Representative
Named) (Recorded File: Trip.com-02-04-251655.MP3.) |
|
7. |
07th-Received: Trip.com sent me another email that requested that I
upload my claims proof (No Representative Named.) |
|
8. |
On “09th of April 9: I made
the “08. 08th-Made Telephone Call” to get the Filses to be able to get
sent Time: 23:44 and another weblink was sent to
me. 08th-Made: Phone Call to Trip.com (No
Representative Named) (Recorded File: 09-04-25.MP3) |
|
9. |
I received the “9th-Received: email
Dated “Thursday 10 April 2025 at 00:19 BST,” where Karl from
Trip.com Customer Success Team, gave me confirmation of receipt where he
indicating he had received my main claim correspondence. However, I later
learned that he failed to forward it to the next case handler, Jobert, in the
Customer Success Team. I
managed to address this issue by the “15. 15th-Sent
Dated” Monday 14 April 2025 at 09:52 BST. 09th-Received: Trip.com Customer Success Team (Karl) –
Request for Baggage Receipts. |
|
10. |
10th-Sent: Response to Baggage Issue Inquiry – Karl (Customer
Success Team. |
|
11. |
11th-Sent: Updated Claim Letter – Correct Version
Attached– Karl (Customer Success Team.) |
|
12. |
12th-Received: Trip.com Customer Success Team (Jobert) –
Acknowledgment & Repetitive Requests. |
|
13. |
13th-Received: Trip.com Customer Success Team (Jobert) –
Follow-Up on Receipts for Verification. |
|
14. |
14th-Received: Trip.com Customer Success Team (Jobert) –
Attempted Case Closure Unless You Respond. |
|
15. |
I was also truly clear about my details of claim that I
contained in all prior correspondence and especially the Table of Contents for the “15. 15th-Sent what is about what had
occurred, and I explained it chapter “03. Journey Details,” about the family who faced
issues alongside with us who were also to be on the same airplane. 15th-Sent: Follow-Up on Claim Submission – Attachments
Provided - From Me (Simon Cordell.) |
|
16. |
It was Shirley Customer Success Team
in the 16. 16th-Received email received by myself
that she agreed that she had acknowledged my feedback regarding the baggage
situation. She also stated “Thank you for providing the full
details of the baggage issue along with the receipts. We will review the
information and get back to you once we have results.” This meant that they
had received the claim
for the first time, as Dated Monday 14 April 2025 at 11:50 BST, due to their
ow faults and negligence. 16th-Received: Acceptance of Receipts - From Shirley (Customer
Success Team.) |
|
17. |
In the 17. 17th-Received:
Dated Tuesday 15 April 2025 at 08:44 BST, Shirley Customer Success Team,
Stated that after reviewing my “Booking And Baggage Details,” Trip.com
had found my purchases. She mentioned that I only requested additional
baggage for the flight from London to Antalya. And this has stayed the basis
of Trip.com’s Defenses as staff have passed the case along to new staff, who
avoid all the official reasons provided in the claim file that served. Trip.com’s staff have
since refused to acknowledge by way of addressing any of the issues I raise
and prove in my supplied claim file. “Shirley Customer Success Team
did say: “There was no request for extra baggage on the
return flight from Antalya to London, which explains why you were charged at
the airport. Therefore, we can only cover the original baggage for your
flight from London to Antalya.” 17th-Received: Trip.com Customer Success Team (Shirley) –
Misrepresentation of Allowance. Date: Tuesday 15 April 2025 at 08:44 BST a. Easy Jet Conversation Between Easy
Jet & Themselves: Date:
Friday 16th of April 2025 from 05:21 BST till 06:37
BST b. Not Disclosed but in the 24th-Received
part Disclosed: Date: Friday
18 April 2025 at 23:58 BST |
|
18. |
In the 18. 18th-Sent: I
had noticed the errors in the way the claim was being handled and therefore
decided to make things in my original main claim letter even more clear. I
explained extraordinarily good reasons for claim and demonstrated reasons for
liability even more so, this included: a.
Misleading Display of the Free 15 kg Allowance b.
Separated Paid-for and Free Baggage Sections c.
Resulting Unexpected Additional
Charges d.
The Return Flight e.
Lack of Clarity in the Paid Package
Section f.
Smart Interface Recommendation g.
Discrepancy in Receipt Date and
Supporting Documentation h.
Operational Impact: Missed Flight
and Resulting Inconvenience i.
Request for Re-Evaluation and Resolute
Caseworker j.
Supporting Documentation |
|
19. |
The 19. 19th-Received: Shirley
Customer Success Team Dated Wednesday 16 April 2025 at 19:34 BST, again
acknowledged my feedback regarding the baggage situation what included my
explanation for the reasons for liability on trip.com behalf for the return
flight also. Shirley Customer Success Team continued by saying: “Thank you for
reiterating what occurred, and we apologize for any delay in addressing your
request. We are reviewing this matter again with the airline and our internal
team, and we will keep you updated once we have results.” This meant that
trip.com were fully aware of what I
was explaining and that this meant that Trip.com’s website and systems “Had Not Operated Correctly In My
Cases And May Be At All Times, Meaning That There Was A Chance Of A Technical
Failure Or System Error, As Was Being Claimed & Proved.” |
|
20. |
20. 20th-Received: Date: Thursday 17 April 2025
at 13:54 BST a. Shirley Customer Success Team Stated: “We sincerely apologize for
the experience you encountered during your recent travel. We
understand how important a smooth journey is and regret any inconvenience caused? b. Shirley Customer Success Team Stated: “We have carefully reviewed
the email you sent regarding the issues faced and have taken the initiative
to check again with the airline to ensure a thorough understanding of the
situation.” c.
Shirley Customer Success Team Stated: “When booking a flight, please be aware that you
have the option to review the baggage allowance included with your ticket.
The details clearly indicate which types of baggage, personal, carry-on, or
checked, are included with the flight. Please refer to the photos below for
reference” ·
They wrongly identified the
claimant. ·
Despite receiving clarification, Trip.com deliberately redacted parts
of the conversation, withholding evidence that would have aided the claim fairly. ·
The initial submission of this claim on 14th April 2025 at 09:52 BST
included proof of misidentification, yet no corrective action was taken. |
|
21. |
21. 21st-Received: Friday 18 April 2025 at
18:46 BST. Krizia Customer Success Team stated: The Trip.com platform clearly
prompts users to add baggage per flight segment, and the booking interface
and confirmation page reflected the same. Your booking included checked
baggage for only one segment of the journey as you only selected baggage for
one segment. Accordingly, the absence of baggage for the return
segment is solely due to your failure to add baggage to the return segment.
There were no errors by Trip.com. |
|
22. |
22.22nd Received: Telephone
Call from Trip.com:
18 April 2025, at 18:48 hours Unnamed Staff: |
|
23. |
23. 23rd-Received: Friday 18 April 2025
at 18:52 BST Possibly unnamed Staff: Auto reply! |
|
24. |
24. 24th-Received: Friday 18 April 2025 at 23:58 BST Krizia Customer Success Team Stated:
a. Easy Jet Conversation Between Easy
Jet & Themselves: Date:
Friday 16th of April 2025 from 05:21 BST till 06:37 BST b. Part Disclosed in the 24th-Received: Date: Friday 18 April 2025 at 23:58 BST |
|
25. |
25. 25th-Received: Saturday 19 April 2025
at 19:45 BST Ray Customer Success Team Stated: “Regarding your flight from London-Antalya to
Antalya-London (order no.1653702646294295, 1653702647563351), I received your
feedback about your baggage concern.” “Following our recent email correspondence, we are
pleased to inform you that, after further investigation, we are able to
compensate you for the baggage allowance fees paid at the airport: GBP 40 at
London Gatwick Airport and GBP 69.63 at Antalya Airport.” “Please confirm if you would like us to proceed
with this compensation process. Upon receiving your confirmation, we will
send a separate email containing an encrypted link for you to securely
provide your bank details for the refund. Please note that the refund
processing timeline may take 7-10 working days and may vary depending on your
bank. “Please be aware that by submitting your bank
account information, you acknowledge and accept the proposed resolution,
which will serve as full settlement of this complaint.” 25th-Received: Trip.com Customer
Success Team (Ray) – Partial “Compensation
Offer!” |
|
26. |
26. 26th-Received: Sunday 20 April 2025 at 17:01 BST Ray Customer Success Team Stated: 26th-Received: Attempted Call from Trip.com,
Follow-Up Email Instead (Ray) |
|
27. |
27. 27th-Received: Sunday 20 April 2025
at 17:07 BST Ray Customer Success Team Stated: 27th-Received: Notification of Unreviewed
Messages (Ray) |
|
28. |
28. 28th-Received: Sunday 20 April 2025
at 23:03 BST Feedback On Your Experience: Auto Reply 28th-Received: Trip.com Customer Satisfaction
Survey Request (No Representative Named) |
|
29. |
29. 29th-Sent:
Monday 21 April 2025 at
18:01 BST By Myself: 29th-Sent: Final Submission of
Pre-Action Conduct Letter & N1 Claim Form |
|
30. |
30th-Received: Final Compensation
Confirmation (Rolly – Bank Details Request) |
|
31. |
31st-Received: Trip.com Customer
Success Team (Rolly – Attempted Closure of Complaint) & (Rolly –
Continued Avoidance of Litigant Fees) |
|
32. |
32nd-Received – Unreviewed
Messages Notification - From Trip.com (No Representative Named) |
|
33. |
33rd-Received – Customer
Satisfaction Survey Request - From Trip.com (No-Reply) |
|
34. |
34th-Sent – Final Submission
of “Pre-Action Conduct Letter” & “N1 Claim Form”
- From Me (Simon Cordell.) |
|
35. |
35. 35th-Received: |
|
36. |
36. 36th-Sent: |
|
37. |
37th-Received: |
|
38. |
38. 38th-Received: |
|
39. |
39. 39th-Sent: |
|
40. |
40. 40th-Received: |
|
41. |
41. 41st-Sent: |
|
42. |
42.
42nd-Received: |
|
43. |
The 43rd Email Received: Monday 19 May 2025 at
13:45 BST. Magali German, EMEA Legal Counsel, Trip.com
Group: a. Easy Jet Conversation Between Easy
Jet & Themselves: Dated:
Friday 16th of April 2025 from 05:21 BST till 06:37 BST. b. Part Disclosed in the 24th-Received: Date: Friday 18 April 2025 at 23:58 BST |
|
44. |
46. File Location Error:
|
|
45. |
45. 45th-Sent: Dated Thursday 22 May
2025 at 15:12 BST |
|
46. |
46. 46th-Received: |
|
47. |
47. 47th-Received: -Response to Final
Notice – Booking Ref. 1653702646294295: Legal Counsel
Escalation: Yet No Resolution After “26
Additional Emails,” Trip.com escalated the issue to “Magali German (EMEA Legal
Counsel, Trip.Com Group)” on “19th May 2025 (43rd Email Received).”
Instead of reviewing the “Documented
Mismanagement,” she “Continued The Trend Of Avoiding Liability.” Failure to
Address Evidence: ·
Response to “43rd email (Dated 19th May 2025,
13:45 BST) ignored the documented misidentification issue. ·
Replying with the “45th email sent (Dated 22nd May
2025, 15:12 BST), Trip.com’s internal file handling failed, further
delaying case resolution. ·
Despite being presented with a fair request for a review, Magali
German became abrupt and dismissive, obstructing a legitimate consumer rights
claim. Dates Between Key
Correspondence ·
Between the “Initial Complaint
(12th January 2025) and
escalations (43rd email on 19th May 2025 and 45th email on 22nd May
2025), extensive legal correspondence took place, yet “Trip.Com Continued Procedural
Evasion.” Continued Refusal to
Accept EasyJet’s Position ·
Despite “Repeated Demonstrations Of
Misidentification Throughout The Claim, Magali German Has Failed To Explain EasyJet’s
Stance Or Provide Necessary Clarifications.”
This deliberate “Avoidance
Of The Facts” mirrors previous teams' handling
strategies. |
|
48. |
48th-Sent-Soon: From: 27/05/25
Sent: 18/06/2025 |
|
49. |
|
|
50. |
|
11. Request for a Fair Review & A
Meeting That I Request For Are Ignored!
·
I Requested a telephone meeting for
clarification of the ongoings ion my claim, but I was ignored and without
justification.
·
Trip.com refuses to acknowledge my key evidence
and their procedural failures and this reckless behaviour constitutes to consumer
right violations.
·
The company Trip.com continues to obstruct any
fair resolution by avoiding legal engagement with the core issues of the claim.
12. Risk Assessment of Procedural
Evasion!
·
Trip.com’s refusal to engage with key evidence
is a violation of consumer rights protections.
·
Failure to review misidentification issues
reinforces procedural misconduct.
·
Magali German’s avoidance of EasyJet’s response
demonstrates deliberate obstruction.
·
Ignoring meeting requests directly impacts
procedural fairness and complaint resolution.
13. Recommended Action!
·
I Formally challenge Trip.com’s legal counsel’s
failure to engage with critical evidence!
·
I Demand recognition of procedural mismanagement
under consumer protection laws!
·
Or else I will escalate the case to regulatory
authorities based on refusal to provide fair review and this will expose
continued negligence in failing to address EasyJet’s involvement and response,
as well as mine.
§ Trip.com’s “Pattern Of
Procedural Evasion Continues To Weaken Its Legal Standing,” reinforcing
the necessity of “Direct Corrective Action And Escalation.”
14. Our Overall Risk Assessment, Trip.com’s
Legal Position is Disintegrating:
1)
Trip.com Civil Restraint Order is a Threat that Contradicts
Singapore Jurisdiction Claims!
·
Trip.com’s
legal counsel has threatened to seek a “Civil Restraint Order (CRO)” to restrict further litigation.
However:
a.
A
“CRO Must Be Issued By A UK Court,” meaning “Trip.Com Must Actively Engage UK Jurisdiction
To Enforce It.”
b.
“CJJA
1982, Section 15B(6)” explicitly prevents companies from enforcing overseas
jurisdiction clauses that “Strip UK Consumers Of Their Local Legal
Rights.”
c.
By attempting to enforce a CRO, Trip.com
contradicts its own claim that UK courts do not have authority over this
dispute.
*
Risk: If Trip.com proceeds with a Civil Restraint Order, it will
be forced to acknowledge “UK Jurisdiction,” directly undermining
its argument for Singapore’s legal priority.
2)
Trip.com Strike-Out
Attempt Under CPR 3.4 Will Strengthen UK Consumer Protections!
·
Trip.com’s
legal team intends to “Seek A Strike-Out Under CPR 3.4,” arguing “No Reasonable
Grounds Exist”
for the claim. However:
a.
“CPR
3.4 Only Permits Strikeouts Where Claims Lack A Legal Foundation,” yet “UK
Consumer Protection Laws Provide Clear Jurisdictional Grounds.”
b.
“Trip.com’s
Prior Engagement With UK Consumers Further Reinforces Jurisdiction Under CJJA 1982.”
c.
“Judicial
Scrutiny will Confirm Trip.com’s Liability And Reinforce Consumer Protections.”
*
Risk: If Trip.com pushes for a strike-out, the claim will “Undergo
Judicial Review,” confirming “Legal Grounds For UK Jurisdiction”
and further weakening Trip.com’s stance.
3)
Hague Convention Exclusion Nullifies Singapore Jurisdiction
Argument!
·
Trip.com’s
legal position “Relies On Contractual Clauses To Enforce Singapore
Jurisdiction,” yet:
a.
“The
Hague Convention On Choice Of Court Agreements (2005), Article 2(1)(A),
Excludes Consumer Contracts” from mandatory jurisdiction enforcement.
b.
“UK
Law Supersedes Contract Restrictions That Override Consumer Protections.”
c.
“Trip.Com
Cannot Legally Argue Singapore Jurisdiction Applies When Consumer Contract
Exclusions Prevent Enforcement.”
*
Risk: Once raised in legal proceedings, “Trip.Com
Will Be Forced To Acknowledge The Hague Convention’s Exclusion,” making its jurisdictional defense unenforceable.
4)
Selective Enforcement of UK Law Exposes Contradictions
·
Trip.com
“Invokes UK Law (CRO Enforcement) While Simultaneously Denying UK Jurisdiction
Over Consumer Disputes.” This contradiction highlights:
a. “If UK Courts Can Issue A Civil
Restraint Order, They Must Also Have Jurisdiction Over The Core Claim.”
b. “Trip.Com Cannot Selectively Rely
On UK Courts For Enforcement While Dismissing UK Consumer Protections.”
c. “Legal Filings Contradict Trip.com’s
Stated Position, Exposing Inconsistencies That Weaken Its Defense.”
*
Risk: By selectively invoking UK law, “Trip.Com
Reinforces Its UK Jurisdiction Obligation,” further exposing inconsistencies in its argument.
5)
Misrepresentation of UK Entity Risks Regulatory Action
·
Trip.com’s
legal counsel “Continues To Misrepresent The Jurisdictional
Position”
of “Trip Air Ticketing (Uk) Limited,” despite:
a.
“Companies
House Confirming It As An Active UK Entity” (source).
b.
“Trip.com’s
Terms & Conditions selectively omitting UK jurisdiction obligations” (source).
c.
“Engagement
with UK consumers reinforcing its legal accountability.”
*
Risk: If formally challenged, “Trip.Com May Face Regulatory
Scrutiny” for “Misleading Corporate Disclosures Affecting UK
Consumers.”
6)
Trip.com’s Critical Misrepresentation of Evidence and a Deliberate
Redaction Identified!
·
Trip.com
“Provided A Partial Screenshot Of Correspondence” related to “Baggage Disputes.” However:
a.
“Exhibited
Evidence (24th-Received) Shows Key Sections Were Redacted,” misrepresenting the dispute.
b.
“A
Full Transcript Later Disclosed (43rd-Received: “Annex 1: Airline “Confirmation
Of Missed Flight And Added Baggage) exposes “Trip.com’s Selective Omission Of
Crucial Details.”
c.
This deliberate redaction aimed to obscure
liability findings, falsely implying an unrelated passport issue.
*
Risk: If this “Evidence Manipulation Is Presented Before UK
Courts, Trip.Com Must Be Liable For Procedural Misconduct And
Potential Regulatory Intervention.”
*
To
facilitate case review, a “Chronologically Indexed Hyperlink Containing
Prior Correspondence” has been provided:
§ Weblink: TripCom-and-Co’s-Correspondence-22-05-2025
§ Exhibit: Annex 1: Airline
confirmation of missed flight and added baggage-Return-1
7)
Trip.com’s Failure to Address Liability due to Contradictory
Saffs Statements About Compensation!
·
Trip.com’s
legal team attempts to “Redefine Compensation As A Goodwill Gesture”
instead of liability recognition, yet:
a. Trip.com’s Official Statement: > “These reimbursements were made as a goodwill
measure and do not imply any admission of liability. They were granted upon
verification of valid receipts and in accordance with our customer service
policy.”
b. Contradictory Internal Communications: > Ray, Trip.com Customer Success Team: > “Following
our recent email correspondence, we are pleased to inform you that, after
further investigation, we are able to compensate you for the baggage allowance
fees paid at the airport: GBP 40 at London Gatwick Airport and GBP 69.63 at
Antalya Airport.”
·
Trip.com
explicitly acknowledged liability as part of an investigation, this was not an
unsolicited goodwill payment.
·
EasyJet’s
confirmation of a disputed baggage charge reinforced Trip.com’s obligation to
compensate. > Ray, Trip.com Customer Success Team: > “The
‘Proposed Resolution’ was to serve as a full settlement of this complaint.”
·
This
confirms the compensation was tied to a legal dispute, not a voluntary goodwill
payment.
·
Multiple
Trip.com representatives failed to align their statements, demonstrating
procedural mismanagement aimed at avoiding liability.
a.
Final Argument on Compensation Misrepresentation
·
Trip.com
“Cannot Retroactively Redefine A Settlement As A Goodwill Gesture” when “Internal
Communications Clearly Confirm Liability Acceptance.” Attempting to reframe compensation “Constitutes
Evasion Of Accountability And Procedural Fairness.”
b.
Conclusion – Trip.com’s Legal Position is Disintegrating!
·
The
“Strategic Miscalculations” made by Trip.com’s legal team have “Collapsed
The Foundation Of Their Defense,” reinforcing UK jurisdiction and consumer protections at
every level.
·
This
response “Dominates Procedurally,” and dismantles jurisdictional contradictions, and “Positions
The Case For Maximum Regulatory Leverage.”
§ Trip.com’s Solicitor Avoiding
Key Evidence, Means that Procedural Evasion is Identified!
c.
Issue: Failure to Acknowledge the Itinerary’s “Processing” Status
& Its Impact on the Claim:
·
Despite
receiving “Organized Past Correspondence” and “Clear Explanations
Of Prior Mishandling,”
Trip.com’s solicitor has “Continued To Evade The Central Issue.” The “Itinerary” remained
marked as “Processing”
at the time of travel,
proving the transaction was “Not Finalized,” yet this evidence
has been “Ignored To Dismiss Liability.”
d.
Legal & Procedural Failures
·
Trip.com’s
system displayed the itinerary as “Processing” at the time of
travel, confirming the booking was incomplete.
·
An
itinerary marked as “Processing” is not a valid receipt,
rendering it inadmissible as proof of purchase.
·
EasyJet
correctly refused to accept the itinerary, as an incomplete booking cannot
serve as a confirmed ticket.
·
Trip.com
refuses to acknowledge this flaw, instead shifting blame onto the consumer for
baggage selection errors.
·
Airport
security footage can verify EasyJet’s rejection of the itinerary, proving
Trip.com’s failure to finalize the booking directly caused financial losses.
e.
Correspondence Evidence Demonstrating Procedural Evasion
·
Emails clearly outlined the itinerary’s invalid
status, documenting Trip.com’s system failure.
·
Despite having access to this evidence, the
solicitor has deliberately ignored the issue, continuing to dismiss liability.
· Trip.com’s legal response focuses on deflection rather than addressing the system failure that directly led to financial losses.
15. Action:
a. “I Demand A Formal Acknowledgment
Of The Itinerary’s Invalid Status In Legal Correspondence.”
b.
“I
request that Trip.Com Holds Itself Accountable For Misrepresentation
Under UK Consumer Law.”
·
Trip.com’s
“Failure To Properly Handle This Claims Issue fairly has Exposed
Its Legal Vulnerability,” reinforcing
the necessity for “Strict Corrective Action.”
Trip.com’s
Solicitor Avoiding Core Claim Issues Is More Than A Procedural Misstep And
Causes Issue Such As A: Failure to Address the Real Reason for the Claim!
·
Despite
clear communication outlining the “Prior Mishandling” of this dispute, Trip.com's solicitor
has “Avoided Addressing The Fundamental Basis Of The Claim.” Instead of engaging with “The
Established Procedural Failings,” she has deflected the issue, failing to rectify the
accountability gaps created by previous teams.
Procedural
Failures Identified
Documented Prior Correspondence Demonstrates Awareness of
These Issues!
· Emails sent clearly outlined how previous Trip.com representatives had engaged in liability evasion tactics.
· Despite these notifications, the solicitor has neither acknowledged nor corrected the structural procedural flaws within Trip.com's handling of the claim.
Kind regards,
Mr. Simon Paul Cordell
This Is a
List of Legal Precedent, Cases That Shows Other UK-Based Consumer Facing
**Similar Issue** With Trip.Com or Another Travel Agency Were UK Law Rules
Jurisdiction.
Some legal precedents related to travel agency disputes and jurisdiction conflicts that support this case:
· Jurisdictional Conflict of Laws Disputes – 3 Hare Court This discusses cases where English courts have ruled on jurisdiction disputes involving foreign travel companies. It includes examples of claims pursued in England and Wales but determined under foreign law, which could be relevant to your argument.
· Cross-border Civil and Commercial Legal Cases – GOV.UK This government guidance outlines how UK courts handle cross-border disputes, including those involving travel agencies and service providers. It explains how jurisdiction can be challenged based on consumer rights and contract terms.
· English Court Rules on Conflicting Jurisdiction and Arbitration Clauses – Mayer Brown This case highlights how English courts have ruled in favor of UK jurisdiction when conflicting clauses exist in contracts. It could be useful if Trip.com tries to enforce their Singapore jurisdiction clause.
These sources provide legal frameworks and precedents that could help challenge Trip.com's jurisdiction argument. Would you like assistance in structuring your response based on these findings?
Consumer Protection Against Unfair Practices
The Consumer Protection from Unfair Trading Regulations
2008 (CPRs) prohibit misleading practices, where Trip.com’s refund process or baggage
selection system was unclear or misleading, this is a violation.