Subject:
Final Submission of Pre-Action Conduct Letter & N1 Claim Form – Booking No.
1653702646294295
Dear Trip.com Customer Success and
Legal Team,
I am writing to formally enclose my “Pre-Action
Conduct Letter”
and completed “N1 Claim Form,”
which detail the unresolved issues surrounding my compensation request. Despite
Trip.com’s acknowledgment of liability, your continued refusal to honor your
own “Customer Service Guarantee” and “Advance Compensation
Policy” leaves me with no option but to escalate this matter further.
1.Key Points in Support of My Claim:
a.Acknowledgment
of Liability:
·Trip.com has “admitted fault”
regarding baggage fees incurred; “£40 At Gatwick” and “£69.63
In Antalya,” but Trip.com staff continues to “Refuse Full
Compensation” for additional losses caused by their service failures.
Specifically, for baggage purchased through their website but
ultimately “Not Provided As Part Of The Service”.
·While both “Departure And Return Flights”are
acknowledged, has
only accounted for certain costs directly “Paid At The Airport,” ignoring
“Original Payments” made through their website that have yet to
be “Fairly Reimbursed.”
·Additionally, compensation has “Not Been
Provided” for “Extra Seats Purchased” to ensure
passengers could sit together, despite these seats being “Paid For Via
Their Platform But Never Honored.”
·Trip.com's “Failure To Fulfill Their
Service Obligations” forced us to travel to a “Different Airport”
and book an alternative flight, “Resulting In Further Unavoidable Costs.”
These expenses are “Clearly Exhibited In The Claim File” with
detailed explanations proving that they were incurred “Through No Fault
Of Our Own,” expenses for which ,” even when their own “Price
Guarantee” explicitly states that full reimbursement is “Protected
In Such Circumstances.”
b.Contradiction
of Policies:
·Your “Customer Service Guarantee” states that verified claims must be
processed within one working day after checkout, yet this timeframe has been
repeatedly breached.
·The
“Advance
Compensation Policy”
promises reimbursement in cases where Trip.com is at fault, further supporting
my entitlement to the requested amounts.
c.Breach
of Disclosure Obligations Under CPR 31.12:
·Trip.com
has failed to acknowledge my formal request for insurance policy disclosure,
which is critical for case analysis. In accordance with “Civ il Procedure Rules (CPR)
31.12,” I reiterate my
request for the immediate provision of all relevant policy documents.
d.Substantial
Financial and Emotional Impact:
·Direct
financial losses include legal fees, client, and legal expenses as well as stress
fees & website analysis fees, total £26,647.19 and additional travel,
and accommodation expenses.
·The
ongoing delays and mishandling have caused significant stress and disruption,
which further amplifies the need for full compensation. £26,647.19.
2.Next Steps:
·Trip.com
must:
a.Confirm
Receipt Of This Submission: and your intention to comply with the
compensation request.
b.Provide
A Clear Timeline For Action: or engage in meaningful alternative
dispute resolution within 14 days.
c.Comply
With The CPR 31.12 Disclosure Request: by providing relevant policy documents
within the same timeframe.
·Failure
to respond adequately will result in the immediate filing of the enclosed “N1
Claim Form”
with the Civil Court,
seeking full compensation, costs, and statutory interest.
·For
transparency, I have attached a “Chronological Summary Of All
Correspondence”
between myself and Trip.com to substantiate my claim.
·I
urge Trip.com to take this opportunity to resolve the matter amicably and avoid
unnecessary legal proceedings. I look forward to receiving your formal
response.
3.Acceptance
of Partial Payment & Continued Claim for Full Compensation:
·“I appreciate Trip.com’s offer to
compensate me”forthe“Baggage
Allowance Fees Paid”at the“London Gatwick Airport of GBP 40” and at“Antalya Airport GBP
69.63.”of “£109.63,” which I accept “Without Prejudice” as a “Partial
Settlement.”
However, this “Does Not Resolve” the full financial losses detailed in my claim, nor does it
account for “Trip.com’s Admitted Liability” for
consequential damages.
a.Settlement Before Court Action:
§✔
If Trip.com “Processes The Full Payment Immediately,” the total compensation remains as
originally requested: 📌£26,647.19, covering expenses up to ‘21/04/2025,’ per the
Pre-Action Conduct Letter.
b.Claim if Litigation Proceeds:
§✔
If Trip.com fails to provide full reimbursement “Within The
Specified Deadline,” the claim will
escalate to court.
§✔
The total amount will then “Increase,” reflecting legal costs, court fees, and
additional expenses incurred “From 21/04/2025 To The Present Date
(07/05/2025), With Ongoing Accruals.”
§📌“Current Total As Of 07/05/2025: £35,306.31,” per the N1 Claim
Form.
§📌
Additional amounts will be added “For Each Day Beyond This Date” until
full resolution.
4.Bank
Details for Processing Partial Payment:
·Should
Trip.com wish to settle the “Original Sum (£26,647.19)” before court action, please process
payment to the following details:
§Account Holder:
Simon Paul Cordell
§Bank Name:[Your Bank]
§Sort Code:[Your Sort Code]
§Account Number:
[Your Account Number]
§Reference:
[Include relevant reference for tracking]
·While
I accept this present offered payment as “Partial Settlement, I Do
Not Waive My Legal Rights”
to pursue the full amount in court if necessary.
5.Legal
Basis for Continued Claim:
·This
claim is legally supported by the following provisions:
1)Consumer Rights Act 2015: Protects consumers from financial
harm caused by unfulfilled service agreements.
2)Civil Procedure Rules (CPR) 46.5: Confirms entitlement to recover costs
incurred by litigants-in-person.
3)CPR 31.12 (Disclosure Request): Requires Trip.com to provide all
relevant policy documents for transparency.
4)Customer Service Guarantee &
Advance Compensation Policy:
Trip.com’s own policies mandate timely compensation.
·I
would also like to remind you that under the “Civil Procedure Rules (CPR)
2014,” litigants-in-person are entitled to recover reasonable costs and
expenses related to pursuing a claim. The legal fees incurred were a necessary
consequence of Trip.com’s inability to resolve my claim
promptly and fairly. Therefore, I request an additional reimbursement to cover
these expenses, which amount to thedetailed invoices provided below!
·It
is crucial to highlight that the compensation offered reflects a partial
acknowledgment of Trip.com legal obligations under the “Consumer
Rights Act 2015.” I request written confirmation that the offered
compensation amountwill be processed promptly.
·By
addressing these issues comprehensively, Trip.com can demonstrate its commitment to
fairness, accountability, and compliance within the United Kingdom’s legal
standards, to be complied with.
Best regards, Simon Paul Cordell Attachments:
·Index
a.Pre-Action
Conduct Letter!
b.N1
Claim Form!
c.Chronological
Summary of Correspondence!
ClaimNo.
IssueDate
Pre Action
Conduct Letter
Claimant Name
a.Name: Simon Paul Cordell
Defendant(S) Name
a.Name: Trip.com Customer Success Team.
b.Name: Trip.com Headquarters, Global
Customer Support Division.
Address Including
Postcode
b.Address 1: 109 Burncroft Avenue
Enfield, London
c.Post
Code: EN3 7JQ.
Address Including
Postcode
c.Postal
Address 1: 9F, Building A, Minhang District,
Shanghai, China, 201107.
This
letter serves as “Formal
Notice” under the “Pre-Action Protocol For Civil Claims In England And Wales.”
1.COMPLIANCE
WITH PRE-ACTION CONDUCT UNDER CIVIL PROCEDURE RULES
Given
that Trip.com has “Already
Accepted Liability,” I formally request the following:
a.Settlement Confirmation:
Full payment of outstanding compensation within “14 days”
of receipt.
b.Alternative Dispute Resolution
Consideration: If full settlement is not confirmed,
Trip.com must engage in “Mediation,
Arbitration, Or Negotiation” within “28 days” before
court proceedings commence.
c.Formal Disclosure of Relevant
Insurance Policies: Under “CPR 31.12,”
Trip.com must provide all relevant policy documents within “14 days,”
ensuring transparency before litigation.
Failure
to comply will result in “Immediate
Legal Escalation,” including a claim for “Costs And Statutory Interest” upon
court filing.
2.UNRESOLVED
COMPENSATION OBLIGATIONS
Despite
“Trip.com’s
admission Of Liability,”you have refused to honor the “Full Compensation”owed, in direct contradiction to your
“Customer Service Guarantee” and “Advance Compensation Policy.”
Additionally,
Trip.com has “Failed
To Acknowledge My Formal Legal Request”
for disclosure of “Relevant
Insurance Policies,” which are critically necessary for
case analysis.
Under
“CPR 31.12,” I formally demand “Specific Disclosure”
of all relevant policies to ensure a fair legal process.
·This includes:
a.Stress Fees: included in the 29. 29th-Sent
b.Additional Client
Expenses: included in the 29. 29th-Sent
c.Legal Fees:
As a “Litigant In Person,” I have undertaken “Significant Legal And Analytical
Efforts” to seek resolution. This case aligns with “Rule 46.5
of the Civil Procedure Rules (CPR),” which entitles litigants to
recover “Reasonable Costs” for their work. Given Trip.com’s
repeated failure to process fair compensation, I am now prepared to
escalate legal proceedings.
3.FORMAL
COMPENSATION REQUEST
·We hereby formally request full
compensation for all losses and damages incurred as a direct result of
Trip.com’s failure to uphold its Customer Service Guarantee and Advance
Compensation Policy. This includes, but is not limited to:
This
is incurred while pursuing this claim and proving financial harm.
Dates:
From 12th January 2025 to 12th
March 2025.
I
have continued to send correspondence since but have not added the
additional fees.
Solicitors
Legal’
Fees:£12,327.50
Solicitors’
Expenses:£197.94
The total sum of
£12,327.50 +
£197.94 is.
£12,525.44
N
Analysis Fees
Structured
investigation required to verify the claim and provide concrete evidence.
If further evidence to prove these claims is requested, it will be
provided.
Dates:
From 12th January 2025 to 12th March 2025.
£8,500.00
M
Client Stress fees
Dates:
Starting
from 12th January 2025 at a
£50.00 Rate! Total £ : Exhibit: M, till the 21/04/2025.
The
duration from 12th January 2025 to 21st
April 2025 is 100 days.
At a
£50.00
Days
× £50.00 per day = £5,000.00
£5,000.00
Pre-Approved
Holiday
Compensation
Your
policies confirm compensation for verified disruptions.
I
request clarity on how my case qualifies.
Pending confirmation
O
Grand Total as of the 21/04/2025
The
total sum of £621.75f5 +
£12,525.44 + £8,500.00 + £5,000.00 is £26,647.19.
4.BREACH
OF TRIP.COM’S OWN COMPENSATION GUARANTEES
·Your “Customer Service Guarantee”
explicitly states:
✔ Verified claims “Must Be Processed Within One Working
Day After Checkout.”
✔“Advance Compensation Policy”
confirms reimbursement when Trip.com is found at fault.
·Given that “Trip.Com Has Acknowledged Fault,” refusal
to process the full reimbursement “Constitutes A Breach Of These Commitments.”
5.FINAL
DEADLINE BEFORE COURT ACTION
·If full settlement is “Not Confirmed Within 14 Days,” I will escalate the matter via an “N1 Claim Form.”
a.This Will Include Filing This Claim
In The Civil Court,” seeking:
✔ Compensation under “CPR 46.5”
✔ Court fees and additional legal
costs
✔ Enforcement of insurance policy
disclosure under “CPR
31.12”
·Additionally, I have attached a “Chronological Record Of All
Correspondence” related to this claim for reference:
🔗All-Emails-TripCom-and-Co.
·This represents “Trip.com’s Final Opportunity”
to resolve this matter “Amicably”
before formal litigation. Kindly provide written confirmation of
compensation and the requested policy documents “Within 14 Days.”
Best
regards, Simon Paul Cordell
VALUE
1.Value (Excluding Legal Fees Incurred After 21st April 2025): The total sum of the amounts
claimed as of 21st April 2025 is as follows:
a.£621.75: Compensation for inconvenience and minor expenses caused by
the defendant's actions.
b.£12,525.44: Reimbursement for consequential losses, such as
missed flights and additional accommodation costs.
c.£8,500.00: Compensation for emotional distress,
disruption, and ongoing inconvenience.
d.£5,000.00: Legal costs associated with filing and pursuing
the claim as a litigant in person.
2.Grand Total: £26,647.19
·This
calculation reflects the claims up to “21st April 2025” and
does not include any legal fees or additional expenses incurred beyond this
date.
Defendant’s
name and
address for service including postcode.
a.Name: Trip.com Customer Success Team.
b.Name: Trip.com Headquarters, Global Customer Support Division.
a.Postal
Address 1: 9F, Building A, Minhang District,
Shanghai, China, 201107.
j.UK
customer service team helpline: 0808 196 9996
Briefdetailsofclaim
Brief Details of Claim:
·This
claim arises from Trip.com’s failure to honor its “Customer Service
Guarantee and Advance Compensation Policy,” despite accepting
liability for additional baggage fees incurred by the claimant at Gatwick
Airport (£40) and Antalya Airport (£69.63).
While Trip.com attempted partial reimbursement, it has refused to
compensate for consequential financial losses and disruptions caused by its
actions.
·The
claim also includes litigation fees, stress damages, and out-of-pocket
expenses directly resulting from Trip.com's negligence and mishandling of
the matter. These costs cover time spent on case preparation,
correspondence, and legal consultations required to navigate the claim.
·Furthermore,
Trip.com’s prolonged delays and failure to resolve the issue have caused
significant emotional distress and disruption to the claimant’s daily life,
for which compensation is sought.
·Additionally,
Trip.com has failed to comply with formal disclosure requests under CPR
31.12, withholding essential documents critical to the claimant’s case
preparation. These failures have further intensified the financial and
emotional impact on the claimant.
·A
detailed chronological summary of correspondence and supporting evidence is
attached to this N1 Claim Form for reference.
Value
1.Grand Total as of the 21/04/2025:
·The total sum of £621.75 + £12,525.44 + £8,500.00 +
£5,000.00 is £26,647.19.
2.New Grand Total:
·Final Invoice Summary:
Category
Amount (£)
Legal Fees (620.12 hours @ £24.70/hour)
£20,194.32
Solicitors’ Expenses
£990.24
Analysis Fees
£8,500.00
Client Stress Fees (100 days @ £50/day)
till the 21/04/2025.
a.Background:
The Claimant, “Simon
Paul Cordell,” brings this claim against “Trip.com,”
including its Customer Success Team and Global Headquarters, for failure to
honor compensation policies despite admitting liability. The claim arises
from misleading information provided at the time of booking, leading to
financial and emotional damages.
b.Admission
of Liability: Trip.com has acknowledged fault
regarding the additional baggage fees incurred at “Gatwick Airport (£40) And
Antalya Airport (£69.63),” yet has refused full reimbursement
for consequential losses caused by its misinformation and failure to
process compensation in accordance with its own policies.
c.Breach
of Consumer Protection and Procedural Rules:
The Defendant has violated multiple contractual and regulatory provisions,
including:
·Customer Service Guarantee:
Trip.com failed to process verified compensation within the promised
timeframe.
·Advance Compensation Policy:
Compensation was refused despite the Defendant’s
clear fault.
·Civil Procedure Rules (CPR) 31.12:
The Defendant failed to disclose relevant
insurance policies necessary for proper case assessment.
d.Financial
Losses and Emotional Impact: Due to Trip.com’s negligence, the
Claimant suffered substantial financial damages, which are concluded but
not limited to:
·Legal fees:“£12,525.44”
incurred while pursuing rightful compensation.
·Analysis Fees:“£8,500.00”
required for structured investigation and verification of financial harm.
·Client Stress Fees:
£5,000.00” for prolonged disruption and emotional distress.
·Unresolved compensation:
£621.75 covering flight-related costs, transportation, and additional
expenses.
e.Failure
to Respond Adequately: The Defendant has been presented
with multiple opportunities to settle this dispute amicably, including
pre-action correspondence detailing all supporting evidence and policy
violations. However, Trip.com has repeatedly failed to:
·Acknowledge the full scope of losses
incurred by the Claimant.
·Process compensation in alignment
with its “Customer
Service Guarantee” and “Advance Compensation Policy.”
·Comply with disclosure obligations
under “CPR
31.12.”
f.Relief Sought:
The Claimant respectfully requests the following relief from the Court:
·Full reimbursement of all losses (£26,647.19).
·Compensation for legal costs.
·Compliance with “CPR 31.12,”
ensuring disclosure of relevant insurance policies.
·Statutory interest as applicable.
§The
Claimant seeks a formal resolution through the Civil Court unless full
compensation is processed within “14 days” from the date of this filing.
2.Chronological
List of Emails and Telephone Calls:
a.01. 01st-Sent Date:
Monday 24 February 2025 at 10:04 GMT: Email Sent: Subject: Ongoing Draft of Complaint - Update
From: Rewired To: service@trip.com; customer.service@easyjet.com;
customer.service@sunexpress.com
b.02. 02nd-Received 1
of 3 Emails for the second response! Date: Monday 24 February 2025 at 10:05
GMT Email Received: Automated
Response from EasyJet Customer Service.
c.02. 02nd-Received 2
of 3 Emails for the second response! Date: Monday 24 February 2025 at 10:04
GMT Email Failed: Failure Notice
when attempting to contact SunExpress Customer Service.
d.02. 02nd-Received 3
of 3 Emails for the second response! Date: Monday 24 February 2025 at
10:08:31 GMT Email Received:
Response from Trip.com Customer Service.
e.03. 3rd Sent Date:
Monday 24 March 2025 at 15:01 GMT Subject: Follow-Up and Request for Resolute Caseworker
Regarding Complaint From: Rewired To: service@trip.com; EasyJet Customer
Service; SunExpress Customer Service.
f.04. 04th-Sent Date:
Friday 28 March 2025 at 11:59 GMT Subject: Follow-up on Previous Correspondence From:
Rewired To: service@trip.com.
g.05. 05th-Received
Date: Wednesday 2 April 2025 at 13:46 BST Email Received: Advertisement from Trip.com.
h.06. 06th-Made By
Me, Making A Call: MP3, I made a telephone call and
i.07. 07th-Received
Date: Wednesday 2 April 2025 at 16:48 BST Email Received: Request to Upload Proof for Order from
Trip.com.
j.08. 08th-Made MP3
09th April 2025 Time: 23:44 BSTTelephone Call Made: Call to Trip.com
Customer Support.
k.09. 09th-Received
Date: Thursday 10 April 2025 at 00:19 BST Email Received: Feedback Request from Trip.com regarding
Booking No. 1653702646294295.
l.10. 10th-Sent Date:
Thursday 10 April 2025 at 21:07 BST Email Sent: Response to Baggage Issue Inquiry – Booking No.
1653702646294295 From: Rewired To: en_flightservice@trip.com.
m.11.
11th-Received-Sent Date: Thursday 10 April 2025 at 23:17 BST Email Sent: Updated Claim Letter – Correct Version Attached
From: Rewired To: en_flightservice@trip.com.
n.12. 12th-Received
Date: Friday 11 April 2025 at 01:14 BST Email Received: Follow-Up from Trip.com regarding Baggage
Issue.
o.13. 13th-Received
Date: Friday 11 April 2025 at 01:18 BST: This email from Trip.com
acknowledges a complaint about a baggage issue on flights between London
and Antalya. They are apologizing for the inconvenience and requesting
proof of the extra baggage fees paid, “£40.00 at Gatwick (Exhibit D)
and £69.63 at Antalya (Exhibit J,)” to investigate the case
further. However, they have overlooked the receipts that were already
attached to the original claim letter, causing unnecessary delays. Their
failure to carefully review the submission suggests a lack of thoroughness
in handling the case. Essentially, they are requesting documentation that
has already been provided, making it necessary to reassert that the claim
was submitted correctly along with the necessary evidence.
p.14. 14th-Received
Date: Saturday 12 April 2025 at 01:49 BST Email Received: Final Follow-Up from Trip.com, mentioning case
closure if no response is received.
q.15. 15th-Sent Date:
Monday 14 April 2025 at 09:52 BST Email Sent: Follow-Up on Claim Submission with Attachments
Provided From: Rewired To: en_flightservice@trip.com.
r.16th-ReceivedMonday,
14 April 2025 at 11:50 BST: Trip.com followed up, acknowledging receipt of attachments
related to this claim and confirming that the documents would be reviewed
to progress the case further.
s.17th-ReceivedTuesday,
15 April 2025 at 08:44 BST: I received a reminder from Trip.com requesting clarification
and additional proof regarding this submitted claim. This email stressed
the need for a timely response.
t.18th-Sent Wednesday, 16 April 2025 at 12:33 BST Email Sent:
Subject: Supplementary Documents for Case
Review From: re_wired@ymail.com To: en_flightservice@trip.com Details:
Submission of additional supporting documents, including updated receipts.
u.19th-Received Wednesday, 16 April 2025 at 19:34 BST Email
Received: Subject: Confirmation of
Receipt of Additional Documents From: en_flightservice@trip.com To:
re_wired@ymail.com Details: Confirmation that the supplementary documents
have been received, and review is ongoing.
v.20th-ReceivedThursday,
17 April 2025 at 13:54 BST: Trip.com responded with a clarification email, highlighting
specific areas that needed further details or corrections to ensure full
review of this case.
w.21st-ReceivedFriday,
18 April 2025 at 18:46 BSTEmail Received: Case escalation
notice from a senior team member at Trip.com who was assigned to oversee
the resolution of the case, indicating progression in the review process.
x.22nd-ReceivedFriday,
18 April 2025 at 18:52 BST: I received
a “Telephone Call From Trip.Com,” during which the senior
case manager
discussed additional confirmation of myself for certain expenses, still.
y.23rd-ReceivedFriday, 18
April 2025 at 18:52 BST: Another follow-up
email from Trip.com reiterated the information shared during the phone
call, stating that they do not accept liability. Once I spoke with a member
of staff, it became evident that the claims and accusations were being
manipulated and that the information provided was being misleading,
diverting attention away from the true nature of the claims.
z.24th-ReceivedFriday, 18
April 2025 at 23:58 BST: Trip.com confirmed
receipt of the information I provided them, both via email and over the
phone. I was unhappy with how the case was being manipulated during the
phone call and requested an email confirming our conversation. However, the
email sent to me does not reflect the details I explained nor address my
request for a copy of the telephone call recording. Instead, it manipulates
the facts in my claim letter to avoid liability. While thanking me for my
cooperation and promising a decision soon, the email disregards the key
points I raised and highlights Trip.com's attempt to shift responsibility
unfairly.
aa.25th-ReceivedSaturday,
19 April 2025 at 19:45 BST: While drafting my
response, which I posted on my disclosed website, I received an email from
Trip.com's Customer Success Team. The email clarified their stance
regarding liability for reimbursement of the claim but still failed to
address the original payment for the lost baggage and the additional costs
incurred.
bb.26th-ReceivedSunday, 20
April 2025 at 17:01 BST:I received an email informing me that a
member of Trip.com staff had attempted to call me regarding the partial
payment they agreed to provide. At that time, I was still preparing a
detailed response to Trip.com, highlighting their price guarantee and
formally requesting reimbursement for my additional losses.
cc.27th-ReceivedSunday, 20
April 2025 at 17:07 BST:I received another Follow-up email in regard to
the missed telephone call.
dd.28th-ReceivedSunday, 20
April 2025 at 23:03 BST: Trip.com asked me
by way of email to provide Feedback on my experience to which I am still
responding.
ee.29th-SentMonday, 21
April 2025 at 18:01 BST: I submitted a
comprehensive response to Trip.com’s requests, addressing all points of
clarification and providing additional evidence as required. In my
response, I also emphasised the importance of Trip.com’s compliance with
their own policies, including the “Customer Service Guarantee And
Advance Compensation Policy.”
ff.30th-ReceivedTuesday,
22 April 2025 at 00:11 BST: Trip.com acknowledged receipt of my response
regarding baggage fees and their “Customer Service Guarantee and Advance
Compensation Policy,” but they refused to comply. Trip.com informed me that
only the baggage fees paid at the airports (£40 at London Gatwick and
£69.63 at Antalya) are refundable—not what was paid through their
website—and that they will not refund my cost to Luton airport. They did
not take any responsibility for the stress I faced, nor for the legal effort
it took to get them to accept liability for the cause of the claim
problems. Trip.com staff also asked me to confirm whether I would accept
this as the only plausible refund offer.
gg.31st-ReceivedWednesday, 23 April 2025 at
00:53 BST:Trip.com sent an email regarding my compensation
claim. While acknowledging liability for the situation, the email failed to
offer reimbursement for the complete losses I have incurred. Instead, it
requested that I accept their current offer as it stands. Additionally, the
email indicated that they are awaiting a reply from me to confirm my
acceptance before proceeding further. In response, I have been diligently
drafting my “Next Email,” including the “Pre-Action
Conduct Letter”
and“N1 Claim Form,” to
address the need for “Recalculating The Complete Settlement”
and ensuring that all consequential losses are fully accounted for, if the “Pre-Action
Conduct Letter” is
not adhered towards.
hh.32nd-ReceivedWednesday, 23 April 2025 at
00:59 BST: I received a duplicate
breakdown of the partially approved reimbursement, including amounts to be
compensated.
ii.33rd-ReceivedWednesday, 23 April 2025 at
23:25 BST: While I was drafting notes to
be agreed upon for the reimbursement of compensation, pending Trip.com's
compliance with their own terms and legal obligations for a fair resolution
of the claim, Trip.com requested feedback from me again.
Note: you are
remindedthat acopyofthisclaimform mustbeservedonall
other parties.
Statementoftruth
Iunderstandthatproceedingsforcontemptofcourtmaybe brought against a person who makes, or causes to be made,
a false statement in a document
verified by a statement of truth without an honest
belief in its truth.
·The claimant booked
a flight through Trip.com’s platform, which presented “Unclear And Inconsistent Baggage Allowance Details.”
·Based on the
information provided during booking, the claimant reasonably believed “Carry-On Baggage Was Included” in the booking.
·Upon arriving at
Gatwick Airport, EasyJet staff informed the claimant that “No Baggage, Neither Carry-On Nor Checked, Was Included” in the booking, despite the claimant's
understanding.
·“Trip.com’s
Response Indicated” that carry-on
baggage had been successfully added to the booking, yet this “Was Not Reflected In The Claimant’s Itinerary” or acknowledged by EasyJet staff at the airport.
·This “Discrepancy Directly Impacted The Claimant’s Ability To Board
Smoothly,” leading to disputes, delays, and financial losses at
both Gatwick and Antalya airports.
2.Contradictory
Information from Airline Staff at the Airport:
·Upon arrival at the
airport, the “First EasyJet Area We Encountered Was The Bag Drop
Check-In Area,” where EasyJet ground operations staff were present.
Given our unfamiliarity with the terminal layout, we reasonably assumed this was the correct
location to check in our baggage. However, after spending time at this
area, it became clear that it was “Solely For Checked Baggage,” leading
to unnecessary confusion.
3.Contradictions Between Trip.com’s
Itinerary and EasyJet’s Policies:
a.Initial
Interaction with EasyJet Staff:
·A staff member
reviewed my “Trip.Com Itinerary On My Mobile Device” and
informed me that “Neither Checked Nor Carry-On Baggage” was included in my booking.
·This was “Contrary
To My Understanding” that I had “Already
Paid For A Carry-On Allowance Through Trip.Com.”
·To confirm, the
staff member checked whether my suitcase fit into the designated sizing
frame and instructed us to ‘Quickly Head Upstairs!’ to
finalise the baggage process.
b.Further
Discrepancies Upstairs:
·Once upstairs,
another “EasyJet staff member claimed my bag was too large,”
without even checking it with a “Baggage Sizer” or “Luggage
Size Checker” and this required
additional payment and despite the fact that “The
Bag Had Already Been Checked Downstairs And Confirmed To Fit Within The
Allowed Dimensions.”
·I explained the
prior verification and pointed out that “My Paid-For Baggage Was Not
Showing On My Itinerary, and I Had Paid For It,” but the staff
insisted that I had to pay again.
·The lack of clarity
between “Trip.com’s booking details and EasyJet’s enforcement of
baggage policies” resulted in my “Baggage
Wrongly Being Refused.”
·Ultimately, I was
forced to “Return Downstairs And Pay For Checked Baggage,”
despite I had paid for additional carryon luggage to Trip.com.
·Even after making
this payment, “The Flight Was Still Missed And Through No Fault Of
Our Own” due to time lost resolving the
baggage dispute.
d.Request for Claim Review:
·The “Failure Of Clear
Communication And The Provision Of Misleading Information” on Trip.com’s
platform directly contributed to the issues faced by the claimant. A formal
review of the claim is requested, considering the following points:
1)Confusion Caused by Trip.com’s Inconsistent Baggage Policy
Presentation:
The
platform's unclear and contradictory information led the claimant to
reasonably believe that a carry-on baggage allowance was included in the
booking, which was later disputed by EasyJet staff.
2)Contradictory Statements from EasyJet Staff: Misaligned instructions from
EasyJet staff at Gatwick Airport resulted in unnecessary financial costs,
logistical delays, and emotional distress.
3)Systematic Misalignment Between Trip.com’s Itinerary Details
and EasyJet’s Baggage Enforcement: The discrepancies between Trip.com’s booking
confirmation and EasyJet’s policies demonstrate a “Clear Failure Of
Transparency,” directly impacting the claimant's ability to
complete their journey without undue inconvenience and financial loss.
·Despite Trip.com's “Admission Of Liability
For Specific Baggage Fees,” they have refused to reimburse the
additional costs incurred as a direct consequence of their failures. This
includes stress-related litigant fees and further consequential expenses.
The claimant asserts that this refusal has now become the “Central
Issue Of The Claim,” highlighting the following:
1)Litigant Fees and Expenses: As a result of Trip.com's
negligence, the claimant has incurred significant legal costs while
pursuing a resolution.
2)Additional Financial Losses: Expenses related to missed
flights, rebooking, accommodation, and transportation remain unresolved.
3)Emotional Distress: The prolonged handling of this
case and lack of a satisfactory outcome has caused ongoing emotional and
logistical strain.
·Trip.com's failure to provide comprehensive
compensation constitutes a violation of fair practice obligations. The
claimant urges the court to recognize this as the core grievance and
requests a fair resolution.
4.Incorrect Assessment of Why My
Flight Was Missed:
·Trip.com's response
inaccurately states that the flight was missed due to travel document
issues. This assertion is “Factually
Incorrect.” The “Primary Factor” contributing
to the delay was the baggage dispute, which stemmed from misleading and
inconsistent guidance provided by Trip.com’s booking system. This dispute
forced the claimant to navigate “Contradictory
Instructions From Airport Staff,”
resulting in lost time and the inability to board as scheduled.
·Had Trip.com
provided “Clear And Accurate Baggage
Information” at the time of
booking, this incident would have been entirely avoidable. The claim that
the airline transferred the claimant to a later flight at no cost does not
negate the “Undue Stress, Inconvenience, And
Financial Losses” incurred due to
the misleading information on Trip.com’s platform.
·Trip.com's
explanation also misunderstands the claimant’s experience using the
platform. The quoted statement, "When Booking A Flight, Please
Be Aware That You Have The Option To Review The Baggage Allowance Included
With Your Ticket," fails to account for the lack of clarity in
the information provided during booking. This statement implies
transparency, yet the claimant's experience demonstrates otherwise.
a.Clarification
of Booking Process:
1)During the multiple
stages of the booking process, passengers are presented with options to add
baggage. The claimant opted to finalise his baggage selection at the last
stage to ensure the best understanding of flight options and suitability.
2)After payment for
additional baggage along with the flight booking, Trip.com sent a
confirmation email allowing access to the claimant's booking account page.
It was only through careful review on this page and at a date too late to
prevent the errors occurred that the “Separation Between
Paid for and Free Baggage Sections”
became apparent, an issue that could not clearly be conveyed earlier.
b.Impact
of Misleading Information:
1)The lack of
transparency and inconsistent details provided by Trip.com led to confusion
at the airport, disputes with airline staff, and forced additional payments
for checked baggage.
2)The claimant’s
ability to board as planned was directly hindered, and subsequent costs and
emotional distress followed as a result.
·The separation between paid and free sections related
to baggage is Exhibited in the attached screenshot.
5.Additional Issues Highlighted: Misleading
Communication and Concealment:
·The confusion was
not entirely caused by the booking process itself but arose when I tried to
verify that I had ordered everything I needed. I reasonably believed the
purpose of the email sent by Trip.com was to provide a “Final, Sealed
Confirmation Invoice That Would Be Easy To Understand.” However, this was not the case.
·A screenshot dated “19th April 2025,” taken from my Trip.com personal account page,
demonstrates the misleading nature of the confirmation process. Following a
telephone call on the “22nd of April 2025,” correspondence with Trip.com staff revealed that
they were unable to access my account due to “Security
Restrictions,” and as a result,
could not review my itinerary or booking confirmation page. I informed them
that I had already included screenshots of these documents in my claim
letter. Their failure to acknowledge these exhibits demonstrates a “Disregard For My
Claim,” necessitating their resubmission as
part of this action.
·In my main claim
letter, I detailed that I became aware of sudden changes to the Trip.com
and EasyJet websites after disclosing the nature of my claims to all
parties held liable. These changes, which began after this disclosure,
appear to have been an “Attempt To Alter or Obscure Critical Information
Related to My Case.” The following
note, titled and dated, illustrates the extent of these changes:
ؓ3) Amendments and Feedback: Thank
you for your understanding and cooperation. Also, Trip.com’s website is
being updated “26-02-2025 at 22:28.”As I reviewed it, I
noticed the changes being made! The “Additional Baggage Allowance” has changed and more.”
·Trip.com’s customer
services, management, and affiliated departments must work in “Coordination” to avoid discrepancies and ensure that consumers
are not misled by contradictory information. Instead, the inaccurate
information initially supplied to customer service and subsequently
repeated in response emails regarding my claims, amounts to a “Systematic
Cover-Up.”
·This cover-up is
evidenced by a lack of communication between management and other
departments, leading to uninformed responses from customer service. It
further appears that Trip.com’s website development and management teams
attempted to rectify the issues I raised, not to “Transparently
Resolve Them,” but rather to limit
liability and protect the company. In doing so, they effectively concealed
my claims, obstructing my ability to pursue rightful compensation. “This
Concealment Can Constitutes to an Illegal Action.”
·Initially, as shown
in the screenshots (Exhibit A1 and Exhibit A2), these
exhibits were located in “Separate Sections” of the website, which “Divided And
Isolated Critical Information.” However, the most recent website
version places both exhibits under the same heading: “Baggage
Allowance.” This heading did not exist at the time of my booking,
and these changes were clearly implemented after the fact.
·Additionally, in
the previous version of the website:
1)Clicking on “Exhibit
A1” and “Exhibit A2” directed users to “Separate Pages.”
2)In the updated
version, both links now redirect to a “Single New Webpage,” consolidating previously separate content. This
new format is cleaner and more user-friendly but was clearly designed to “Prevent Customers
From Encountering The Contradictory Information That Led To My Experience.”
·To Illustrate These
Changes, I Have Provided The Following:
1)Screenshots of the “New
Website Layout,” presented in two parts.
2)An additional
weblink demonstrating the revised interface.
3)“Comparative
Images” of the original website layout for
context.
·When you click on the button titled at the bottom of
the webpage that states “View Additional Baggage,” the next
screenshot is where you get directed to.
·The next screenshot below is taken from the original
website layout that I used to book my orders.
6.Issues
with Trip.com's Website Navigation and Baggage Information:
·Within the Trip.com website, the “Navigation Menu” is designed as an index for
navigating through large quantities of content. Typically, navigation menus
should ensure that titles and associated links provide consistent and
transparent information. However, Trip.com’s website “Failed To Adhere To This Standard Protocol,”
leading to confusion and misinformed decisions by the claimant.
·Specifically, the ‘Top Menu
Link For’ “Baggage Allowance” directed users to a section
labeled as “Free” baggage allowance. However, further down
the webpage, a separate weblink redirected to a different page detailing “Paid Baggage Options.” This inconsistency created “Contradictory Pathways,” which are not typical of standard
website navigation practices designed to ensure user clarity.
1)Such
discrepancies in links can cause consumers to make decisions based on “Incomplete
or Misleading Information,” as
was the case here.
·Across the entirety of Trip.com’s
website, there was “No Direct Explanation or Link”
provided regarding EasyJet’s policy for the ‘15kg Free Carry-On’ “Personal Item.” Instead,
the baggage allowance information appeared vague and incomplete. Consumers
could easily confuse the free 15kg carry-on allowance offered by EasyJet
with Trip.com’s “15kg Paid Additional Baggage
Allowance,” which lacked clear differentiation.
·As evidenced in “Exhibit B1,” the
original weblink associated with the “Baggage Allowance”
title directed users to a specific page. This page, as demonstrated in the
exhibit, highlights the misleading design and division of information
between “Free”
and “Paid”
baggage options.
1)“Exhibit
B1 Screenshot”further illustrates how the lack of
clarity in web navigation contributed to the claimant’s misunderstanding
and subsequent financial loss.
7.Impact
of Misleading Web Navigation:
1)The separation and inconsistent
labeling of baggage information links caused confusion for the claimant,
resulting in “Misinformed Decisions”
during the booking process.
2)The “Failure To Provide Transparent Information”
regarding EasyJet’s free baggage policy at the time of booking forced the
claimant into unnecessary additional purchases and logistical challenges.
3)Trip.com’s website design did not
follow “Best Practices For Clarity And
Consistency,” which are industry standards to
prevent such consumer challenges.
·The original weblink directed you to the following
screenshot below!
8.Website
Design Flaws and Consumer Confusion:
·“Exhibit B2 and
Exhibit B3,” as displayed in the screenshots,
appear directly above and below each other on Trip.com's website. This
arrangement caused significant confusion due to their unclear and ambiguous
presentation.
·Consumers using the Trip.com website
were unable to clearly identify the purpose of “Exhibit B2” and “Exhibit B3,” as neither link provided sufficient
explanation:
1)Exhibit
B2: led consumers to believe it
represented “Paid Baggage Options.”
2)Exhibit
B3: appeared to represent “Free Baggage Allowance,” such as the 15kg carry-on baggage
allowance offered by EasyJet.
·However, the lack of any explicit
description or explanation distinguishing these links meant that customers
could easily confuse “Paid Baggage Options With Free
Baggage Allowances,” as was the case for the claimant.
1)Specifically,
the absence of guidance created the perception that the free 15kg allowance
was part of the “Paid Baggage Section,”
misleading consumers into unnecessary purchases.
·For the claimant to fully understand
the intended purpose of these links, it was necessary to click on both
links, located in “Separate Sections Of The Webpage,”
without any clear instructions or contextual guidance. This design flaw
deviates from standard user-friendly website practices, which aim to
provide transparency and minimize confusion.
·Demonstrating the original second “Baggage
Allowance Button” weblink!
9.Evidence
of Website Modifications and Misleading Title Changes:
·As shown in “Exhibit C1,”the
original title “Additional Baggage Allowance” has since been “Altered,”
reflecting changes made to Trip.com’s website. This modification
demonstrates an effort to address design flaws, though it lacks
transparency regarding the initial discrepancies.
·Below, the original weblink button
titled “Additional Baggage Allowance”is shown in the
attached screenshot. This button previously redirected users to a page that
created confusion regarding the distinction between “Free” and “Paid-For Baggage
Options.” The lack of clear differentiation at the time of booking
misled the claimant and contributed to the issues highlighted in this case.
·Below is what the original weblink
button tiled as “Additional Baggage Allowance!” what directed
you to the following screenshot below!
·Background: The claimant has presented evidence, supported by a recorded
video and screenshots, which highlights significant flaws in Trip.com's
website navigation and the misleading presentation of baggage information
during the booking process. The claimant details their experience
navigating Trip.com’s platform and subsequent issues, demonstrating the
lack of clarity that led to confusion and financial losses.
13.Key
Points:
a.Original
Website Design:
·The claimant accessed Trip.com’s
website to manage their booking and verify their purchased options. Upon
receiving the itinerary email, which was described as a "Sealed
Document," they reasonably believed it contained complete and
accurate information.
·While navigating the site, two "Baggage
Allowance" sections were identified:
1)One
pertaining to “Free Baggage,”
such as EasyJet's 15kg allowance.
2)The
other pertaining to “Paid Baggage Options.”
·Both sections were ambiguously titled
and visually similar, causing confusion about what was free versus paid.
b.Website
Updates Post Complaint:
·Following the claimant’s formal
complaint, Trip.com updated the website design. The previously separate "Baggage
Allowance" links now direct users to the same consolidated
page.
·This update lacks transparency,
appearing to resolve the confusing layout while attempting to obscure the
original design flaws.
c.Consumer
Impact:
·The claimant mistakenly believed they
had purchased a 15kg baggage allowance. Upon reviewing the itinerary, they
discovered only “Free Baggage” information was listed, which
conflicted with what had been paid for.
·Extensive research and comparison
with EasyJet’s policies confirmed the 15kg allowance was actually free,
revealing how Trip.com’s website layout misled consumers into purchasing
unnecessary baggage options.
d.Evidence
Presented:
·The claimant has provided the
following exhibits to substantiate their claims:
1)Exhibit
C1: Original email and itinerary
reflecting ambiguous baggage details.
2)Exhibit
C2: Screenshots of the original "Baggage
Allowance" sections, illustrating how free and paid baggage
information were misrepresented.
e.Conclusion:
Trip.com's misleading website design, combined with subsequent edits made
after the claimant’s complaint, contributed to significant confusion and
financial losses. These updates suggest an attempt to conceal the original
flaws rather than addressing them transparently. The claimant contends that
this constitutes a failure in consumer protection and calls for fair
compensation.
1.Itinerary:Evidence of Booking
Access & Discrepancies in Account Review:
·Upon
completing my purchase, I received an email from containing a link to access my bookings page. This page provides
an option to download my itinerary as a PDF, which I have attached below as
supporting evidence.
·Failure by to Access Booking Records: During a telephone conversation on the “22nd-Received-Tel-Call,”
Trip.com staff informed me that they were unable to access
my account due to “Security Challenges.” As a
result, they claimed they could not review my booking confirmation page or
itinerary.
·Pre-Action Submission of Exhibits & Lack of
Acknowledgment: I previously provided “Screenshots
Of Key Exhibits” in my formal claim letter, ensuring had access to all relevant booking details. However, their failure
to properly acknowledge these exhibits demonstrates a “Disregard For
My Claim” and an attempt to avoid accountability.
·Re-exhibition of Key Documents: Given Trip.com’s refusal to
recognize the original evidence provided, I have “Re-Exhibited
Several Essential Files,” reinforcing my position and ensuring that
the court has a complete record of the disputed booking details. These
documents directly support my claim regarding compensation entitlements and
Trip.com’s failure to uphold its customer service obligations.
§Exhibit:
21
2.Additional
“Key Points” & Issues Identified in the Itinerary:
a.The
Itinerary Above Proves That:
·The itinerary provided by Trip.com
was marked as "Sealed" at the time of issuance on “Wednesday,
8th December 2024,” yet it remained incomplete and displayed the
status of "Processing!". This status has persisted
up until “Friday, 25th April 2025” as confirmed when the
claimant logged into Trip.com’s website and downloaded the itinerary again.
The failure to finalize and update this document over this extended period
demonstrates negligence and a lack of transparency in handling the
claimant’s booking.
b.Incomplete
Information on Baggage Allowance:
·The itinerary fails to clearly
differentiate between “Free Baggage Allowances”
(Such As EasyJet’s 15kg Carry-On
Allowance) and “Paid Baggage
Options” purchased by the claimant. This ambiguity likely
caused confusion during the booking and travel process.
c.Contradictory
Statements:
·Despite mentioning “Processing!”
alongside additional baggage purchased, the itinerary implies that the
transaction remains unresolved, leading the claimant to question whether
the paid baggage option was valid or accessible during travel.
·The lack of updated confirmation
contradicts the expectation of a “Sealed And
Finalized Invoice” provided by Trip.com.
d.Unclear
Layout and Missing Explanations:
·The itinerary lacks sufficient
textual guidance for interpreting key sections, such as baggage
information, flight details, and required documents.
·The absence of clear headers and
detailed explanations forces the user to manually decipher the content,
contributing to unnecessary complexity.
e.Failure
to Reflect Airline Standards:
·The itinerary provides no indication
of EasyJet’s standard policy allowing free carry-on baggage as a personal
item, which is a “Key Aspect Of Transparency”
for travelers.
f.Confusing Section Placement:
·The placement of the baggage
allowance information at the “Bottom Of The
Itinerary” undermines its importance, as users
must search through unrelated sections to find critical details.
g.Misleading
Information:
·The itinerary suggests that no free
baggage allowance exists, which contradicts EasyJet’s standard policy for
personal items. This misrepresentation might lead consumers to purchase
unnecessary baggage options under false pretenses.
h.Lack
of Clear Instructions for Airport Procedures:
·Important information about checking
in, required documents, and boarding instructions is buried in an “Unclear Format,” making it harder for travelers to
prepare adequately for their flights.
2.Chronological Breakdown of
Activities, Fees & Markers
·The time periods for Regular
Hours, Overtime Hours, and Night Shift
Hours based on a typical workday starting at 9:00 AM:
a.Regular Hours:
·Typically,
these are the standard working hours during the day.
·Start Time: 9:00 AM
·End Time: 5:00 PM
b.Overtime Hours:
·These
are hours worked beyond 5:00 PM up until 9:00 PM,
assuming a normal 8-hour workday.
·Start Time: 5:00 PM
·End Time: 9:00 PM
c.Night Shift Hours:
·Night
shift hours are generally recognised as any work done between 9:00
PM and 6:00 AM the following morning.
·Start Time: 9:00 PM
·End Time: 6:00 AM
14.Correspondence
Management:
·The implementation
of this relatively new law introduced may cause a significant challenge for
many companies unfamiliar with its details. The lack of clarity regarding
final values and grand totals has necessitated for me to develop for this
claim a robust system of documentation, including detailed receipts and
explanatory texts. This initiative-taking approach has not only enabled me
to align with the “Litigation Act (2014)” but also to understand its legal scope, potential
for recovery of cost, and most of all its importance in achieving fairness
and justice.
15.Ensuring
Fairness and Preventing Abuse:
·While the law
demonstrates remarkable capacity for recovery, it also presents
opportunities for misuse if left unchecked. The absence of strict caps on
final values is of utmost importance due to the unique demands of each case
and varying work durations that may arise. Placing a grand total cap would
undermine the ability to account for these unique circumstances. Instead,
we have ensured that compensation practices remain “Fair, Transparent, And Procedurally Correct” to prevent abuse and ensure compliance with
litigation standards. This structured framework balances the law's
flexibility with necessary safeguards against exploitation.
16.The
Role of Regular, Overtime, and Night Shift Hours:
·The legal right to
claim “Regular Hours, Overtime Hours, And
Night Shift Hours” is unquestionable.
However, this flexibility can inadvertently result in compensation
imbalances, particularly when calculating lengthy shifts. To prevent unfair
totals, boundaries have been established to ensure equity, aligning with
compliance under the “Litigation Act (2014)” and United Kingdom’s laws.
17.Overtime Hours: Strict 4-Hour Limit:
·Overtime is
carefully monitored and capped at “4 Hours Per Day,” ensuring compliance with necessary rest
requirements under the “Working Time Regulations (1998).” This structure prioritizes worker safety while
providing reasonable compensation for additional hours worked. Limiting
overtime prevents excessive claims and ensures consistent standards across
compensation practices.
18.Night Shifts: Organized for Equity at a Lower
Rate:
·To further enhance
fairness and prevent inflated claims, “Night Shift Hours”
are compensated at a rate of £30.88/hour,
which is intentionally lower than the overtime rate. This approach
acknowledges the distinct nature of night shift work while ensuring
compensation remains equitable and procedurally correct. By organising
night shifts with structured boundaries, we prevent the possibility of
calculating night shifts at higher sums or combining them unfairly with
extended overtime hours, which could inflate totals beyond what is
reasonable under the law.
19.Monitoring
Compliance Under the Working Time Regulations (1998):
·While the UK has no
specific law defining a "Maximum Overtime Hours Per Day," the
“Working Time Regulations (1998)” provide critical safeguards to ensure fairness
and prevent exploitation:
a.48-hour
weekly limit: Averaged over a 17-week period unless an opt-out
agreement is in place.
b.Rest
periods:
Workers are entitled to “11 consecutive
hours of rest within a 24-hour period.”
·These requirements
indirectly limit the total working hours per day, ensuring compliance with
health and safety standards and promoting fairness.
20.Night
Shift Rates and Procedural Compliance:
·To maintain
compliance with the “Litigation Rules (2014),” night shift rates have been structured at £30.88/hour.
This rate ensures compensation remains “Fair, Transparent,
And Defensible,” aligning with
legal and procedural standards.
a.Night shift rates
are deliberately set lower than overtime rates to prevent inflated
calculations and ensure equity.
b.This approach
reflects the distinct workload and conditions of night shifts, ensuring
fairness without compromising compliance.
·By adhering to
these principles, the structured system of Regular Hours, Overtime Hours,
and Night Shift Hours ensures all claims are calculated and compensated in
a manner that is both equitable and compliant. Transparency and organised boundaries
maintain the integrity of the law while preventing misuse.
21.Refined
Table of Correspondence with Times and Breakdown:
Task: Made a phone call to Trip.com to address weblink
issues “Accepting Only Image Files;” transcribed the MP3
recording, filed it into exhibits, and sent a formal claim letter with
receipts.
Sent
updated evidence and documents for baggage inquiries, with attached
receipts (£40 and £69.63).
2
hours
£49.40
£0
£0
£49.40
15. 11th-Sent
Thursday,
10 Apr 2025 - 23:17 BST
Resent
corrected claim letter with additional documents to address issues caused
by Trip.com stating they did not receive the files. This email includes
an additional Microsoft word Docx Document of the claim along with a PDF
file.
3
hours
£49.40
£37.05
£0
£74.10
16. 12th-Received
Friday,
11 Apr 2025 - 01:14 BST
Trip.com
requested additional proof and clarification about baggage receipts,
requiring further communication and clarification. This caused extra work
to clarify the breakdown in communication regarding the receipt of
official documents.
5
hours
£49.40
£111.15
£0
£160.55
17. 13th-Received
Friday,
11 Apr 2025 - 01:18 BST
Trip.com
sent duplicate email requesting receipts; reviewed this correspondence
and made clarifications.
15
mins
£6.18
£0
£0
£6.18
18. 14th-Received
Saturday,
12 Apr 2025 - 01:49 BST
Drafted
a response to earlier emails, addressing Trip.com's claim of case closure
within 24 hours; this caused significant “Stress” as to the
additional effort.
30
mins
£12.36
£0
£0
£12.36
19. 15th-Sent
Monday,
14 Apr 2025 - 09:52 BST
Resent
attachments and compiled prior correspondence; detailed effort over
multiple days addressing Trip.com’s missing documents.
a.12 April: 13
hours
b.13 April: 13
hours
c.14 April: 0.87
hours
Total: = 13 + 13 + 0.87 = 26.87 hours
This Included:
a.-10. 10th
Sent-Claim-for-TripCom.pdf
b.-10. 10th
Sent-Claim-for-TripCom.docx
c.All-Emails-TripCom-and-Co.docx
26.87
hours
£345.80
£148.20
£123.52
£765.70
20. 16th-Received
Monday,
14 Apr 2025 - 11:50 BST
Reviewed
Trip.com’s response, indicating further delays in processing the claim.
2
hours
£49.40
£0
£0
£49.40
21. 17th-Received
Tuesday,
15 Apr 2025 - 08:44 BST
Acknowledged
Trip.com’s misunderstanding of claim letter and partial acceptance of responsibility,
requiring clarification of liability. Their partial acceptance of
responsibility appears to divert focus away from their own
accountability, what further complicated the resolution process for the
claimant.
2
hours
£49.40
£0
£0
£49.40
22. 18th-Sent
Wednesday,
16 Apr 2025 - 12:33 BST
Drafted
rebuttal to Trip.com's claims, reasserting evidence and clarification of
reimbursement demands.
3.5
hours
£86.45
£0
£0
£86.45
23. 19th-Received
Wednesday,
16 Apr 2025 - 19:34 BST
Analyzed
Trip.com's position contesting fees and requesting additional
clarification.
2.5
hours
£61.75
£0
£0
£61.75
24. 20th-Received
Thursday,
17 Apr 2025 - 13:54 BST
Acknowledging
Trip.com's response, which partially addressed the claimant’s concerns
but still deflected full responsibility by attributing fault to the
claimant, Trip.com failed to confirm whether the claim had been
officially filed in order to avoid liability. As a result, the claimant
was required to provide further evidence and clarification to ensure the
claim was properly understood and addressed, causing additional delays
and efforts.
3
hours
£74.10
£0
£0
£74.10
25. 21st-Received
Friday,
18 Apr 2025 - 18:46 BST
Acknowledging
Trip.com's response, which demonstrated only a partial understanding of
the claimant's correspondence, further clarification was necessary. This
email compelled the claimant to expend additional time and effort to
address and correct Trip.com's misinterpretation of the claim and its key
points, thereby causing further “Unwanted Stress!”
3
hours
£74.10
£0
£0
£74.10
26. 22nd-Received
Friday,
18 Apr 2025 - 18:48 BST
Acknowledging
Trip.com's “Telephone Call,” during which they appeared to reinterpret the
claimant's statement in a way that minimized their liability. By reading
between the lines, Trip.com seemingly diverted responsibility and shifted
focus away from the clear points made in the original claim letter. This
approach not only imposed additional obstacles on the claimant but also
appeared to test the claimant's resolve through an impromptu call,
thereby complicating the process further. Subsequently, I documented the
recording and updated the claim files to accurately reflect the details
discussed.
2.5
hours
£61.75
£0
£0
£61.75
27. 23rd-Received
Friday,
18 Apr 2025 - 18:52 BST
While
preparing my response, I received multiple emails from Trip.com. By the 21st
Email, it became clear that Trip.com intended to undermine my
claim by misrepresenting the facts. This forced me to reorganize and
refile all the exhibits to clarify my position more effectively. During
this process, I also received the 22nd Telephone Call,
which revealed Trip.com’s evasive tactics aimed at avoiding liability by
distorting my claim. Subsequently, I received the 23rd Email and
Two Additional Emails, some of which were related to the 22nd
Telephone Call, all while I was still preparing my response.
4
hours
£98.80
£0
£0
£98.80
28. 24th-Received
Friday, 18 Apr 2025 - 23:58 BST
Acknowledged
Trip.com's request for feedback on the claimant’s experience, balancing
constructive feedback with formal complaint preparation.
3 hours
£74.10
£0.00
£0.00
£74.10
29. 25th-Received
Saturday, 19 Apr 2025 - 19:45 BST
While
drafting my response to the 20th And 21st Emails, I
received a telephone call from Trip.com’s Customer Services
what isthe 22ndCorrespondence. I continued working on my
response while receiving Two Additional Emails, and this
process continued until I received the 25th Email were they
“Accepted Liability as Trip.Com & Co.” Upon receiving
this email, I changed my approach and redrafted new correspondence to
address the missing sums, setting aside the previous draft. During this
time, I also received three more emails while preparing the
Second Document that needed to be sent. Additionally, I
reviewed Trip.com’s offer for an out-of-court settlement and analyzing
their strategic diversion approach.
4 hours
£98.80
£0.00
£0.00
£98.80
30. 26th-Received
Sunday, 20 Apr 2025 - 17:01 BST
I
continued monitoring Trip.com's interpretation of claim evidence hosted
on horrificcorruption.com to ensure proper representation of the facts.
Trip.com
manager Ray made an attempted to call me and sent me an email to this
effect as I was not available to chat.
2 hours
£49.40
£0.00
£0.00
£49.40
31. 27th-Received
Sunday, 20 Apr 2025 - 17:07 BST
While
preparing my response I acknowledge another email from Trip.com manager
Ray who sent me a follow-up email reminding me of his attempted telephone
call, which prompted significant effort to refine my strategy and adapt
to the evolving complexity of the case.
9 hours
£0.00
£148.20
£61.76
£209.96
32. 28th-Received
Sunday, 20 Apr 2025 - 23:03 BST
Acknowledging
Trip.com's request for feedback on the claimant’s experience, which
coincided with the claimant’s preparation of a formal complaint. This
timing added further complexity to an already demanding process,
requiring the claimant to balance providing constructive feedback with
addressing unresolved issues. Trip.com's prioritisation of feedback over
resolving the evidence - backed claims demonstrated inefficiency and
contributed to unnecessary delays in the claimant’s pursuit of
resolution.
3 hours
£74.10
£0.00
£18.54
£92.64
33. 29th-Sent
Monday, 21 Apr 2025 - 18:01 BST
The second document I made was sent
rather than the first document as the 29th Email, and was filed Accordinglyto “Trip.com’s Customer
Service Guarantee,”
Turnaround Response Reflecting
Strategic Focus and Accountability:
1.Acknowledgment of Liability
Acceptance:
·Trip.com had accepted liability for the core claims at
this stage, and the claimant used this response to solidify their
position and align the next steps accordingly.
2.Request for Compensation of
Stress and Legal Fees:
·The claimant explicitly detailed the request for
compensation for stress and legal expenses as a litigant in person,
including costs incurred from engaging clients and legal support. These
requests were framed within the context of established legal principles.
3.Request for Insurance
Documentation:
·The claimant requested access to Trip.com's insurance
documents as part of the evidence-gathering process, ensuring
transparency and compliance with procedural requirements.
4.Breakdown of Fees and Legal
Compliance:
·The response provided a thorough explanation of fees,
ensuring all claims adhered to relevant legal regulations and principles.
This reinforced the claimant’s adherence to procedural integrity while
holding Trip.com to the same standard.
5.Reiteration of
Total Losses and Warning of Legal Action:
·The claimant called for Trip.com
to fully compensate for the documented losses and explicitly stated that
failure to comply would result in the issuance of an N1 Claim Form.
This underscored the seriousness of the matter while maintaining
professionalism.
6.Strategic Shift
in Approach:
·This response represented a
decisive pivot, balancing firm demands with legal precision to
effectively advance the claim while adhering to core principles of
fairness and accountability.
17 hours
£197.60
£148.20
£154.40
£500.20
34. 30th-Received
Tuesday, 22 Apr 2025 - 00:11 BST
Response Reflecting Trip.com’s
Failures and Breaches:
Trip.com's response, stating they would "only be able to refund
baggage charges incurred at the airport," represents a glaring
disregard for their broader obligations and guarantees. By failing to
address the full extent of their liability, they have violated.
Since the 30th Email, I have used the message originally
intended for the 25th Email that I created before receiving
their acceptance of liability but refusal to pay reasonable costs.
There unfair refusal has since prompted me to prepare a “Pre-Action
Conduct Letter” and an “N1 Claim form,” as
reviewing their correspondence revealed the need for further
clarification regarding their failure to honor guarantees and thoroughly
investigate my claims. These issues added complexity to the case
preparation, highlighting Trip.com's failure to honor guarantees in
correspondence and addressed incomplete claims.
17 hours
£197.60
£148.20
£154.40
£500.20
35. 31st-Received
Tuesday, 22 Apr 2025 - 00:53 BST
Clarified
unresolved liability issues and finalized response to Trip.com's
reimbursement proposal.
17 hours
£197.60
£148.20
£154.40
£500.20
36. 32nd-Received
Wednesday, 23 Apr 2025 - 00:59 BST
Prepared
formal pre-action letter and N1 Claim Form ensuring accurate breakdowns
and attached exhibits.
17 hours
£197.60
£148.20
£154.40
£500.20
37. 33rd-Received
Wednesday, 23 Apr 2025 - 23:25 BST
Finalized
submission of correspondence and attached all evidence alongside the
prepared N1 Claim Form.
17 hours
£197.60
£148.20
£154.40
£500.20
38. 34th-Sent
Sunday, 27 Apr 2025
Submitted
the completed court bundle, including the N1 Claim Form, evidence, and
correspondence summary.
Claimant's Strategic Response:
1.Formal Submission of Pre-Action
Letter and N1 Claim Form:
·The
claimant enclosed the “Pre-Action Conduct Letter” and the completed “N1 Claim Form,” officially escalating the matter
and asserting legal grounds for compensation.
2.Key Issues Raised: a. Acknowledgment of
Liability:
·The
claimant highlighted Trip.com's admission of liability for specific
baggage fees while emphasizing their failure to compensate for additional
losses incurred due to service failures.
b. Breach of Guarantees:
·Trip.com
violated their own “Service Guarantee and
Advance Compensation Policy,” which promise timely resolution and reimbursement for
claims where fault is admitted.
c. Failure to Disclose Insurance Policies (CPR
31.12):
·The
claimant reiterated their request for Trip.com to provide relevant
insurance documentation, a key procedural requirement under the “Civil Procedure Rules.”
d. Substantial Financial and Emotional Impact:
·Direct
financial losses included legal fees (£25,110.00), analysis fees
(£12,327.50), and consequential expenses from disrupted travel.
·The
claimant also addressed significant stress and disruption caused by
Trip.com’s mishandling of the claim.
3.Compensation Demands:
·The
claimant formally requested full compensation for losses, including
stress fees, legal expenses, and consequential damages.
·Trip.com
was notified of the claimant's intent to escalate to court proceedings if
their obligations remained unmet.
4.Call for Procedural Compliance:
·The
claimant urged Trip.com to confirm receipt of the submission, provide a
clear timeline for action, and comply with the disclosure request to
avoid legal escalation.
5.Acceptance of Partial Payment
“Without Prejudice”:
·While
acknowledging the goodwill gesture for travel expenses, the claimant
emphasized that partial
4.Trip.com
Claim – Business Fees and Internet Usage Costs:
a.Communication Costs:
Item
Cost per Unit (£)
Phone Calls
£0.10 per call
Internet Usage
£2.00 per GB
Postage (Letters)
£0.85 per letter
b.Explanation
of Business Fees:
·Virgin Media does
not charge per GB because their service provides “Unlimited Data” for a fixed monthly fee of “£55 per month.” However, since this internet service is being
used for “Business
Purposes,” I apply a “Cost Rate Per GB” to calculate how much each liable party should
pay for its usage.
·Even though Virgin does
not bill this way, I treat internet usage as a “Measurable Business
Expense,” similar to how companies charge for service consumption.
Instead of simply stating "I paid £110,"
I break down how much of that cost was “Used By Each Claim” using the “Per-GB Model.”
·Additionally, I was
“Trapped
Into A Contract” with Virgin Media
Voom 600, where the service was originally priced at “£55 Per Month.” Since then, Virgin has “Reduced The Price,” and I am disputing the “Additional Cost” under Virgin’s terms and conditions that I am
still paying.
·Between “12th
January 2025 and 10th March 2025,” I “Did Not Apply Business Fees” to my invoice as a “Goodwill Gesture.” Despite this, I have now been forced to do so
due to “Trip.com’s
Refusal” to cover my “Legal Fees And
Additional Costs,” even though they have “Accepted Liability.”
·As of “10th March 2025,” the rate has been set at a “Fair Business Charge Of £4.00
Per GB” to ensure that my service “Generates A Return On
Investment” while covering
operational costs.
·“Cost Calculation for All Liable Parties”
c.Step
1: Virgin Media Cost
·From 12th January 2025 To 10th March 2025, “Is 58 Days In Total!”
✔January:
12th to 31st → 20 days.
✔February:
Full month → 28 days.
✔March: 1st
to 10th → 10 days.
·From 10th March 2025 To 4th May 2025, “Is 56 Days In Total!”
✔March: 10th
to 31st → 22 days.
✔April: Full
month → 30 days.
✔May: 1st to
4th → 4 days.
·The Newest Calculations are for the 10th of March 2025 till 04th
of May 2025:
1)Monthly
cost: £55
2)Total
cost for two months (56 days):
3)£55×2
= £110.00
d.Step
2: Data Usage at £4.00 per GB
·Since the actual usage is now
adjusted to 40 GB, we calculate:
·40 GB×£4.00 per GB = £160.00
·This ensures £50.00 profit
while fully recovering Virgin’s cost.
e.Step
3: Proportional Share Breakdown
·Each Liable Party Is Responsible For
A Percentage Of Usage:
·“Trip.Com And Thameslink Are Paying Their Fair Share” based on actual business-related
internet usage.
·“Virgin Media’s Cost Is Fully Recovered,” ensuring no personal financial
burden.
·“A £50 Profit Margin Is Applied,” reflecting the administrative effort
required to manage claims and handle business expenses.
h.Trip.com’s Communication Costs Table
(Phone Calls, Internet Usage, Postage-Letters.)
Item Number
Date & Time
Item
Cost per Unit (£)
Task
Item Used
Quantity
Total (£)
#01
12 January 2025 when we arrived back home.
till
12 Mar 2025 once I had completed my claim letter!
Phone
Calls
£0.10
per call
Preliminary Review (Daily Usage)
Tick If Used
☒
1 call
£0.10
12 Jan – 12 Mar 2025
Internet
Usage
£2.00
per GB
Tick If Used
☒
52.49 GB
£41.93
12 Jan – 12 Mar 2025
Postage
(Letters)
£0.85
per letter
Tick If Used
☒
0 letters
£0.00
End of Items
Total: £42.03
·The
communication costs for this period were “Split Proportionally”
based on workload percentages for each claim:
a.Trip.com: 40%
b.Southern Rail: 30%
c.Dentafly Clinic: 30%
·This
method ensures fairness in distributing costs. The total sum of £105.08
was divided accordingly, considering how much time, effort, and data usage
each claim required.
·For
instance, internet usage was calculated by determining the “Daily
Cost Of Virgin Media (£1.81 Per Day)” and multiplying it by the
number of days in the claim period (58 days), resulting in “£104.98
For Data Usage.”
·Each
claim was then assigned a “Proportional Share” of expenses
based on workload percentages, ensuring an equitable split.
Item Number
Date & Time
Item
Cost per Unit (£)
Task
Item Used
Quantity
Total (£)
#02
Monday, 24 Feb 2025 - 10:04 GMT 10:05 GMT
15:01 GMT
Internet
Usage
£2.00
per GB
Researching Complaint Procedures
Tick If Used
☒
1 Day
1.11GB
£2.22
Monday, 24 Feb 2025 - 10:04 GMT 10:05 GMT
15:01 GMT
Phone
Calls
£0.10
per call
Drafting Initial Complaint Email
Tick If Used
☒
0 call
£0.00
Monday, 24 Feb 2025 - 10:04 GMT 10:05 GMT
15:01 GMT
Postage
(Letters)
£0.00
per letter
Preparing Comprehensive Complaint Letter
Tick If Used
☒
0 letters
£0.00
End of Items
Total: £6.00
·For Internet usage we evenly distribute 40GB
over 36 days, we calculate:
·40GB ÷ 36 days =
1.11GB per day
·So, the daily usage rate is
approximately 1.11GB per day.
·Meaning that 1.11GB costs £4.44 at
the £4.00 per GB rate.
#02 Formula:
1.11GB x 1
Days = 1.11GB
£2.00 × 1.11GB
= £2.22
·1st email sent this is
already included in the first quote!
1)09.
09th-Received Date: Thursday 10 April 2025 at 00:19 BST Email Received: Feedback Request from Trip.com regarding Booking No.
1653702646294295.
2)10. 10th-Sent
Date: Thursday 10 April 2025 at 21:07 BST Email Sent: Response to Baggage Issue Inquiry – Booking No.
1653702646294295 From: Rewired To: en_flightservice@trip.com.
3)11.
11th-Received-Sent Date: Thursday 10 April 2025 at 23:17 BST Email Sent: Updated Claim Letter – Correct Version Attached
From: Rewired To: en_flightservice@trip.com.
Item Number
Date &
Time
Item
Cost per Unit (£)
Task
Item Used
Quantity
Total (£)
Friday, 11th Saturday, 12th
Sunday, 13th Apr 2025
Internet Usage
£4.00 per GB
Reviewing & Responding to Multiple Emails
Tick If Used
☒
2 Days
2.22GB
£8.88
#09
Friday, 11th Saturday, 12th
Sunday, 13th Apr 2025
Phone Calls
£0.10 per call
Tick If Used
☒
0 call
£0.00
Friday, 11th Saturday, 12th
Sunday, 13th Apr 2025
Postage (Letters)
£0.85 per letter
Tick If Used
☒
0 letters
£0.00
End of Items Total:£5.12
#09 Formula:
1.11GB x 2
Days = 2.22GB
£4.00 × 2.22GB
= £8.88
1)12. 12th-Received Date: Friday 11
April 2025 at 01:14 BST Email Received: Follow-Up
from Trip.com regarding Baggage Issue.
2)13. 13th-Received Date: Friday 11
April 2025 at 01:18 BST: This email from Trip.com
acknowledges a complaint about a baggage issue on flights between London
and Antalya. They are apologizing for the inconvenience and requesting
proof of the extra baggage fees paid, “£40.00 at Gatwick (Exhibit
D) and £69.63 at Antalya (Exhibit J,)” to investigate the case
further. However, they have overlooked the receipts that were already
attached to the original claim letter, causing unnecessary delays. Their
failure to carefully review the submission suggests a lack of
thoroughness in handling the case. Essentially, they are requesting
documentation that has already been provided, making it necessary to
reassert that the claim was submitted correctly along with the necessary
evidence.
3)14. 14th-Received Date: Saturday
12 April 2025 at 01:49 BST Email Received: Final
Follow-Up from Trip.com, mentioning case closure if no response is
received.
Item Number
Date &
Time
Item
Cost per Unit (£)
Task
Item Used
Quantity
Total (£)
Monday, 14th
Apr 2025 - 09:52 BST
Internet Usage
£4.00 per GB
Drafting "Pre-Action Reminder"
Tick If Used
☒
2 Days
2.22GB
£8.88
#10
Monday, 14th
Apr 2025 - 09:52 BST
Phone Calls
£0.10 per call
Tick If Used
☒
0 call
£0.00
Monday, 14th
Apr 2025 - 09:52 BST
15th
Postage (Letters)
£0.85 per letter
Tick If Used
☒
0 letters
£0.00
End of Items Total: £5.12
#10 Formula:
1.11GB x 2
Days = 2.22GB
£4.00 × 2.22GB
= £8.88
1)15. 15th-Sent Date: Monday 14
April 2025 at 09:52 BST Email Sent: Follow-Up on Claim Submission
with Attachments Provided From: Rewired To: en_flightservice@trip.com.
2)16th-ReceivedMonday, 14 April 2025 at 11:50
BST: Trip.com followed up,
acknowledging receipt of attachments related to this claim and confirming
that the documents would be reviewed to progress the case further.
3)17th-ReceivedTuesday, 15 April 2025 at
08:44 BST: I received a reminder
from Trip.com requesting clarification and additional proof regarding this
submitted claim. This email stressed the need for a timely response.
Item Number
Date &
Time
Item
Cost per Unit (£)
Task
Item Used
Quantity
Total (£)
Tuesday, 15th
Wednesday, 16th
Thursday 17th
Apr 2025
Internet Usage
£4.00 per GB
Analyzing Trip.com’s Responses
Tick If Used
☒
2 Days
2.22GB
£8.88
#11
Monday, 14th
Tuesday, 15th
Wednesday, 16th
Thursday 17th
Apr 2025
Phone Calls
£0.10 per call
Tick If Used
☒
0 call
£0.00
Monday, 14th
Tuesday, 15th
Wednesday, 16th
Thursday 17th
Apr 2025
17th
Postage (Letters)
£0.85 per letter
Tick If Used
☒
0 letters
£0.00
End of Items Total: £5.12
#11 Formula:
1.11GB x 2
Days = 2.22GB
£4.00 × 2.22GB
= £8.88
1)18th-Sent Wednesday, 16 April
2025 at 12:33 BST Email Sent: Subject: Supplementary Documents for
Case Review From: re_wired@ymail.com To: en_flightservice@trip.com
Details: Submission of additional supporting documents, including updated
receipts.
2)19th-Received Wednesday, 16
April 2025 at 19:34 BST Email Received: Subject: Confirmation
of Receipt of Additional Documents From: en_flightservice@trip.com To:
re_wired@ymail.com Details: Confirmation that the supplementary documents
have been received, and review is ongoing.
3)20th-ReceivedThursday, 17 April 2025 at
13:54 BST: Trip.com responded
with a clarification email, highlighting specific areas that needed
further details or corrections to ensure full review of this case.
Item Number
Date &
Time
Item
Cost per Unit (£)
Task
Item Used
Quantity
Total (£)
Friday, 18 Apr 2025 - 18:52 BST
Internet Usage
£4.00 per GB
Creating Detailed Pre-Action
Reminder
Tick If Used
☒
2 Days
2.22GB
£8.88
#12
Friday, 18 Apr 2025 - 18:52 BST
Phone Calls
£0.10 per call
Tick If Used
☒
0 call
£0.00
Friday, 18 Apr 2025 - 18:52 BST
19th
Postage (Letters)
£0.85 per letter
Tick If Used
☒
0 letters
£0.00
End of Items Total: £5.12
#12 Formula:
1.11GB x 2
Days = 2.22GB
£4.00 × 2.22GB
= £8.88
1)21st-ReceivedFriday, 18 April 2025 at 18:46
BSTEmail Received: Case escalation notice from
a senior team member at Trip.com who was assigned to oversee the
resolution of the case, indicating progression in the review process.
2)22nd-ReceivedFriday, 18 April 2025 at 18:52
BST: I received a “Telephone
Call From Trip.Com,” during which the senior case manager discussed additional confirmation of myself
for certain expenses, still.
3)23rd-ReceivedFriday, 18 April 2025 at 18:52 BST: Another follow-up email from Trip.com reiterated the
information shared during the phone call, stating that they do not accept
liability. O with a member of staff, it became evident that the claims
and accusations were being manipulated, and that the information provided
was being misleading, diverting attention away from the true nature of
the claims.
4)24th-ReceivedFriday, 18 April 2025 at 23:58 BST: Trip.com confirmed receipt of the information I
provided them, both via email and over the phone. I was unhappy with how
the case was being manipulated during the phone call and requested an
email confirming our conversation. However, the email sent to me does not
reflect the details I explained nor address my request for a copy of the
telephone call recording. Instead, it manipulates the facts in my claim
letter to avoid liability. While thanking me for my cooperation and
promising a decision soon, the email disregards the key points I raised
and highlights Trip.com's attempt to shift responsibility unfairly.
5)25th-ReceivedSaturday, 19 April 2025 at 19:45 BST: While drafting my response, which I posted on my
disclosed website, I received an email from Trip.com's Customer Success
Team. The email clarified their stance regarding liability for
reimbursement of the claim but still failed to address the original payment
for the lost baggage and the additional costs incurred.
1)26th-ReceivedSunday, 20 April 2025 at 17:01 BST:I received an
email informing me that a member of Trip.com staff had attempted to call
me regarding the partial payment they agreed to provide. At that time, I
was still preparing a detailed response to Trip.com, highlighting their
price guarantee and formally requesting reimbursement for my additional
losses.
2)27th-ReceivedSunday, 20 April 2025 at 17:07 BST:I received another Follow-up email in regard to the
missed telephone call.
3)28th-ReceivedSunday, 20 April 2025 at 23:03 BST: Trip.com asked me by way of email to provide Feedback
on my experience to which I am still responding.
Item Number
Date &
Time
Item
Cost per Unit (£)
Task
Item Used
Quantity
Total (£)
Monday, 21 Apr 2025 - 18:01 BST
Internet Usage
£4.00 per GB
Tick If Used
☒
1 Day
1.11GB
£4.44
#14
Monday, 21 Apr 2025 - 18:01 BST
Phone Calls
£0.10 per call
Preparing Chronological Summary
for Submission
Tick If Used
☒
0 call
£0.00
Monday, 21 Apr 2025 - 18:01 BST
Postage (Letters)
£0.85 per letter
Tick If Used
☒
0 letters
£0.00
End of Items Total: £2.56
#14 Formula:
1.11GB x 1
Days = 1.11GB
£4.00 × 1.11GB
= £4.44
1)29th-SentMonday, 21 April 2025 at 18:01 BST:
I submitted a comprehensive response to Trip.com’s requests, addressing
all points of clarification and providing additional evidence as
required. In my response, I also emphasised the importance of Trip.com’s
compliance with their own policies, including the “Customer Service Guarantee And Advance
Compensation Policy.”
Item Number
Date &
Time
Item
Cost per Unit (£)
Task
Item Used
Quantity
Total (£)
Tuesday, 22 Apr – Wednesday, 23 Apr 2025
Internet Usage
£4.00 per GB
Tick If Used
☒
2 Days
2.22GB
£8.88
#15
Tuesday, 22 Apr – Wednesday, 23 Apr 2025
Phone Calls
£0.10 per call
Final Correspondence, Review
& Filing
Tick If Used
☒
0 call
£0.00
Tuesday, 22 Apr – Wednesday, 23 Apr 2025
Postage (Letters)
£0.85 per letter
Tick If Used
☒
0 letters
£0.00
End of Items Total: £5.12
#15 Formula:
1.11GB x 2
Days = 2.22GB
£4.00 × 2.22GB
= £8.88
1)30th-ReceivedTuesday, 22 April 2025 at 00:11 BST: Trip.com acknowledged receipt of my response
regarding baggage fees and their “Customer Service Guarantee and Advance
Compensation Policy,” but they refused to comply. Trip.com informed me
that only the baggage fees paid at the airports (£40 at London Gatwick
and £69.63 at Antalya) are refundable—not what was paid through their
website—and that they will not refund my cost to Luton airport. They did
not take any responsibility for the stress I faced, nor for the legal
effort it took to get them to accept liability for the cause of the claim
problems. Trip.com staff also asked me to confirm whether I would accept
this as the only plausible refund offer.
2)31st-ReceivedWednesday, 23 April 2025 at
00:53 BST:Trip.com sent an email regarding my compensation
claim. While acknowledging liability for the situation, the email failed
to offer reimbursement for the complete losses I have incurred. Instead,
it requested that I accept their current offer as it stands.
Additionally, the email indicated that they are awaiting a reply from me
to confirm my acceptance before proceeding further. In response, I have
been diligently drafting my “Next Email,” including the “Pre-Action
Conduct Letter” and“N1 Claim Form,” to address the need
for “Recalculating The Complete Settlement” and ensuring
that all consequential losses are fully accounted for, if the “Pre-Action
Conduct Letter” is not adhered towards.
3)32nd-ReceivedWednesday, 23 April 2025 at
00:59 BST: I received a duplicate breakdown of the
partially approved reimbursement, including amounts to be compensated.
4)33rd-ReceivedWednesday, 23 April 2025 at
23:25 BST: While I was drafting notes to be agreed
upon for the reimbursement of compensation, pending Trip.com's compliance
with their own terms and legal obligations for a fair resolution of the
claim, Trip.com requested feedback from me again.
Other Compensation (Flights,
Taxi, Baggage, Food, Hotel, E.g.)
Exhibit
Reference: A, F, G. “Trip.com Invoice of Purchases.” £216.90
Exhibit
Reference: B. “Taxi Costs” £51.50
Exhibit
Reference: C. “Omio Train Tickets” £53.40
Exhibit
Reference: D. “EasyJet Baggage Charge” £40.00
Exhibit
Reference: H. “Additionally Transportation” £46.00
Exhibit
Reference: I. “Food & Drink Expenses” £23.00
Exhibit
Reference: L. “Hotel Costs”
£120.32
Exhibit
Reference: J. “Antalya Airport Baggage Charge”
£69.63
£621.75
Grand Total
£35,306.31
3.Our
Notes:
a.The “383
Hours” reflect time spent from “12th of
January 2025 To 12th of March 2025,” as confirmed in “Email 15, Section 07.”
b.All subsequent
tasks (Emails 1–31) and their respective time allocations are
calculated in addition to the 383 hours.
c.From March 10th of March 2025 till the 04th
of May 2025, a total of“56 days”, have passed, during which “620.12 hours”
were spent working as a litigant on the Trip.com official case files.
d.The “MP3 Recordings”
reflect the effort needed to document and extract actionable points from
verbal correspondence.
1.Legal
Precedent for Recovering Costs in Public Interest Litigation:
·One compelling example of
successfully claiming legal costs and expenses is “R (Unison) v Lord Chancellor
[2017] UKSC 51.” In this landmark Supreme Court case,
“Unison,”
a trade union, challenged the introduction of “Employment Tribunal Fees,”
arguing that they unlawfully restricted “Access To Justice.”
The Supreme Court ruled in favor of Unison, declaring the fees “Unlawful” and
striking down the legislation that introduced them.
·This ruling reinforced the principle
that litigants forced to challenge “Unfair Policies” should
not be burdened with financial barriers that prevent them from seeking
justice. As the winning party, Unison was entitled to claim, “Legal
Costs” and “Expenses Incurred” throughout the case, including “Solicitor And Barrister
Fees,” expert analysis costs, and other associated
expenses.
·The significance of this case lies in
its clear recognition of how procedural failures by institutions can
necessitate litigation. As such, the precedent “Supports Claims For Legal
Costs” where claimants, acting “In Good Faith,” are
forced to engage in complex legal action due to a defendant's refusal to
resolve disputes fairly. This aligns directly with the “Civil Procedure Rules (CPR)
46.5,” which entitle litigants-in-person to claim “Reasonable Costs”
associated with preparing and pursuing their case.
1.Reimbursement Request & Next Steps:
·Given the “Lack
Of Clarity” during booking and
“Misalignment” between Trip.com’s itinerary details and
EasyJet’s enforcement, I request a formal review of my claim for
reimbursement. Specifically, I request compensation for the additional
charges paid due to incorrect baggage classification:
a.Direct
Financial Losses Incurred:
·These costs are a
direct consequence of Trip.com's misleading booking system and EasyJet’s
failure to recognize the added carry-on baggage allowance at check-in.
b.Original Website Fees:
·Additional Baggage:
·Seats:
c.Airports
Baggage Fees Paid, Due to Misrepresentation:
·£40.00 at Gatwick
Airport: Forced to pay for checked baggage
due to EasyJet staff incorrectly claiming no baggage was attached to the
booking.
·£69.63 at Antalya
Airport: Additional unexpected baggage cost
upon return flight due to same misclassification issue.
d.Additional
Expenses Caused by the Missed Flight:
·£46.00 Train fare
(Gatwick → Luton): Incurred to
rebook after EasyJet refused boarding.
·£23.00 Food
expenses (Luton Airport):
Cost incurred while awaiting new travel arrangements.
·£120.32 Hotel
accommodation: Required due to
missed flight and forced rebooking.
·StressFees: Beyond direct financial losses, Trip.com’s “Negligent
Handling, Misleading Booking Process, And Repeated Refusal To Properly
Investigate” have led to
significant stress, inconvenience, and financial strain. £50.00 Daily
inconvenience rate (starting from 20 March 2025): Ongoing personal
disruption caused by handling the claim.
·Legal Fees and
Expenses incurred: £25,110.00 Legal Fees: Costs related to advocacy, research,
correspondence, and case preparation.
f.Accountability for Misleading
Consumer Practices:
·Trip.Com Knowingly
Misrepresented Baggage Policies: through deceptive website layouts and visual
elements, forcing unnecessary purchases.
·They Failed To
Provide A Clear, Verifiable Booking Itinerary, resulting in contradictions with EasyJet staff
and forcing additional payments.
·Their Responses
Continuously Avoid Key Findings,
causing unnecessary delays, which contributed to financial, emotional, and
logistical distress.
I urge you to reconsider your decision and take
responsibility for the misleading presentation of baggage details on your
booking platform, which contributed to significant financial and logistical
disruption. Kindly review my claim again and provide a fair resolution.
I look forward to your response.
Best regards, Mr. Simon Paul Cordell
P.S.
Here is a consolidated list of all the key issues
that Trip.com has “Either Avoided Or Misrepresented” in their responses:
Checklist of
Unresolved Issues in Trip.com’s Responses:
a.Misleading Baggage Information During Booking:
·Issue: Trip.com’s website
implied that carry-on baggage was included, but EasyJet staff later
claimed, “No Baggage Was Associated With The Booking.”
·Impact: This led to
last-minute confusion at the airport.
·Previously
Mentioned In:
1)Complaint Letter
(Booking Process Section)
2)Emails on 10 &
14 April 2025
b.Contradictory Information from Airline Staff at the
Airport:
·Issue: Different EasyJet
staff members gave “Conflicting Instructions” on whether my bags was acceptable.
·Impact: Led to wasted
time, extra costs, and ultimately missing my flight.
·Previously
Mentioned In:
1)Complaint Letter
(Exhibit E – EasyJet Supervisor’s Response)
2)Email on 28 March
2025
c.Confusion Caused by Inconsistent Itinerary Details:
·Issue: Your itinerary “Did
Not Reflect The Added Carry-On Baggage,” causing rejection by EasyJet staff.
·Impact: Forced unnecessary payments for checked baggage.
·Previously
Mentioned In:
1)Emails on 10 &
14 April 2025
d.Unjustified Airport Charges for Baggage:
·Issue: You were charged “£40 at
Gatwick” and “£69.63
at Antalya” due to misleading
baggage policies.
·Impact: Financial loss
caused by lack of clear booking information.
·Previously
Mentioned In:
1)Complaint Letter
(Exhibits D & J)
2)Emails with
Trip.com (Karl & Jobert, 10–12 April 2025)
e.Misrepresentation of Why the Flight Was Missed:
·Issue: Trip.com claims my
flight was missed due to “Travel Document Issues,” ignoring
that it was about the baggage dispute.
·Impact: Deflects
responsibility for misleading baggage handling.
·Previously
Mentioned In:
1)Email on 17 April
2025
2)Complaint Letter
(Journey Details Section)
f.Failure to Assign a Resolute Caseworker:
·Issue: Multiple requests
for “A Resolute Caseworker” to oversee my complaint were ignored.
·Impact: No streamlined
resolution or accountability.
·Previously
Mentioned In:
1)Email on 24 March
2025
2)Follow-up on 28
March 2025
g.Lack of Transparency in Baggage Policy Links:
·Issue: Trip.com “Did
Not Provide Direct Airline Policy Links” before purchase, leading
to assumptions about baggage inclusion.
·Impact: Created confusion
about what was actually included.
·Previously
Mentioned In:
1)Complaint Letter
(Booking Experience Section)
2)Email on 10 April
2025
h.Misleading Use of Images to Push Baggage Fees:
·Issue: Booking platforms—including Trip.com—use
deceptive practices to misrepresent baggage policies.
Passengers are manipulated into believing they
must “Pay For Any Suitcase,” even when airline policies allow certain
personal and carry-on baggage at no extra cost. This practice results in “Unnecessary
Spending” and confusion at check-in.
·How Manipulation is Achieved:
1.
Misleading Visual Aids
·Booking platforms “Deliberately
Depict Only Rucksacks” as acceptable
personal items on flights.
·This “Excludes
Suitcases” from visual representations, “Creating
The False Impression” that passengers
must pay extra to bring standard carry-on baggage.
i.Lack of Clear Text-Based Descriptions:
·“No Clear Statements” explaining that “Small,
Medium-Sized, And Large Suitcases” can
qualify as personal or carry-on baggage under most airline policies.
·This omission “Leads
Passengers To Assume They Cannot Bring A Suitcase Without Paying An
Additional Fee.”
j.The Reality: Airline Policies vs. Booking Site
Representations:
·“99% Of Airlines
Allow A Broad Range Of Personal Items,” including different sizes of suitcases, as long
as they meet “Weight And Size Regulations.”
·“Trip.Com And
Similar Platforms Misrepresent These Policies,” leading consumers to believe restrictions exist
when they do not.
k.Uniform Manipulation Across Travel Platforms:
·The “Systematic Use”
of misleading visuals and ambiguous descriptions is “Consistent Across Multiple Booking Agents.”
·This creates “Widespread Confusion,”
compelling passengers to “Purchase Baggage
They Might Not Actually Need.”
l.Contradictory Information on EasyJet’s Website &
Video:
·“EasyJet’s Official
Baggage Policy Does Not Require Passengers To Pay For Carry-On Suitcases” if they fit within the airline’s specified
dimensions.
·However, “Trip.com’s
Interface Displays Contradictory Baggage Requirements” that mislead
customers into believing additional baggage fees are mandatory.
·A “Specific
Video On EasyJet’s Website”
intended to clarify baggage rules “Was Unavailable,” yet its content “Still
Exists And Contradicts What Was Presented At Booking.”
1)Extract
from EasyJet Video: Exhibit A1 (referenced)
2)Archived
URL:
horrific-corruption-files.webhop.me/PNC66/1. .
PNC-Errors-and-Its-Other-Claims/05-01-25-till-25-01-25-File-Locked4Sharing/Teeth-14-01-25/02.
Trip Com And Airlines-Claim-PartSent/00.
Cabin-Bags-Explained-EasyJet-27-02-25/
·Conclusion:
Trip.com and other platforms “Intentionally
Mislead Consumers By Manipulating Visuals And Policy Descriptions,” resulting in passengers “Wrongly
Believing They Must Pay For A Suitcase.” The inconsistencies between “EasyJet’s
Official Policy, Trip.com’s Booking Interface, And The Missing Yet
Contradictory Video Evidence Further Reinforce The Deceptive Nature Of
These Practices.”
10. Opaque Revenue
Model for Baggage Fees:
Issue:
Trip.com “Prioritise Baggage Fees As A Separate
Revenue Stream” rather than
aligning with airline policies.
Impact:
Customers may “Unnecessarily” pay for luggage that should be included.
Previously Mentioned In:
1)Complaint Letter
(Baggage Revenue Analysis)
2)Email on 24
February 2025
11. Repetitive
Excuses Instead of Proper Review:
Issue:
Trip.com continually uses “Generic Responses” about baggage policies instead of directly
addressing your concerns.
Impact:
Prevents a “Proper Investigation”into
misleading booking details.