Duff on Hospitality Law

Good evening from the ALIS Conference in Los Angeles . . . Our travel-shortened Online Travel Update for the week ending January 23, 2026, is below. This week’s Update features a wide variety of stories, including updates on two stories we featured last week – Airbnb’s evolving hotel aspirations and investigations into Trip.com’s allegedly anti-competitive practices. I hope you enjoy.

• • To Allow AI Agents or Not to Allow AI Agents – That Is the Question. I’ve been a part of these discussions with several clients over the past few weeks. We definitely know Amazon’s perspective on this question, though as Perplexity has argued in recent court filings, Amazon appears to be engaged in the very same behavior that it is now seeking to stop by Perplexity. This week’s first story from PhocusWire provides a number of arguments in favor of allowing AI agents.
  • ChatGPT to Test Advertising. This past week, OpenAI announced that it would soon test sponsored ads in responses delivered to logged-in users of ChatGPT’s free and new Go tiers (users of ChatGPT’s higher subscription tiers will continue to enjoy ad free responses). No one should be surprised. At some point, these platforms, which require huge financial investments to sustain and grow, had to commercialize their platforms and extensive user bases. Significant questions remain about the newly announced advertising product (including, most importantly for hoteliers, how ads may be purchased, prioritized, etc.), but OpenAI did share some initial guiding principles about the product:
    
    • “Organic” AI responses will not be influenced by the advertisements
    • OpenAI will not sell users’ personal information to advertisers
    • Advertisements will only appear for logged-in users and will not appear alongside sensitive topics like personal health or politics

While travel was not specifically identified in the announcement, a sample screen shot included in the announcement featured a sample travel response and related advertising. For anyone still debating whether AI platforms (and related advertising) need to be addressed in your internal and external distribution discussions, this latest OpenAI announcement should be a call to action.

Have a great week everyone.

Good Sunday evening from a sunny Seattle . . . Our first Online Travel Update for 2026 is below. This week’s Update features new stories on China’s possible crack down on Trip.com, an update on Airbnb and its plans for hotels and the latest from Google and its rapidly evolving agentic platform. I hope you enjoy.

• • Trip.com Under Investigation for Alleged Monopolistic Practices. Trip.com announced this past week that it had received a notice of investigation from the State Administration for Market Regulations of the People’s Republic of China (“SAMR”). According to the notice, the investigation stems from Trip.com’s alleged abuse of its dominant market position through coercive contract terms, arbitrary increases in commission fees and the blocking of internet traffic. If found guilty of violating China’s Anti-Monopoly Law, Trip.com can be fined between 1% and 10% of its total annual revenue from the previous year (a similar investigation into the practices of Alibaba resulted in record $2.5 billion fine).
  • Changes Afoot at Airbnb. Last week, Airbnb announced that it had hired Meta’s former head of generative AI, Ahmad Al-Dahle, as its new CTO. According to CEO Brian Chesky’s letter to employees introducing Ahmad, Ahmad “connects big ideas with technical depth, highly values design, and believes engineering should be a true strategic partner.” Perhaps more important for my readers, our friend and industry colleague, Lou Zameryka, announced this week on LinkedIn that he is joining Airbnb to lead its hotel efforts (Lou’s announcement was confirmed by an announcement yesterday from Airbnb where it announced Lou as its new Global Head – Hotel Enterprises and Connectivity Partnerships). Congratulations to Lou. If anyone still doubts Airbnb’s intentions with regard to AI or its move (again) into hotels, it may be time to re-consider. There was a reason why we included an Airbnb story on its re-entry into hotels as one of seven featured stories in our 2025 year-end review.
  • Google’s Latest Agentic Announcement Presents New Opportunities for Travelers and Suppliers. At last week’s National Retail Federation annual conference, Google introduced its Universal Commerce Protocol (UCP), which is designed to allow AI agents to complete purchases (or bookings) within a conversational user interface. Although UCP was developed with retail product purchases in mind (and the announcement featured some of the country’s largest retailers – including Target and Walmart (though, interestingly, not Amazon)), the protocol was developed to handle more complex transactions (i.e., travel). In theory, the newly announced protocol should allow travelers to discover, search, select and book (the entire sales funnel) travel within a single platform without the need to jump from platform to platform (which we’ve noted in multiple previous posts as being one of the biggest challenges to currently available AI platforms). For suppliers, the new protocol allows them to remain the merchant of record and “own” the customer relationship, fulfillment and post-purchase relationship.

Have a great week.

Happy New Year . . . Our annual “year in review” Online Travel Update is below. We’ve enjoyed having the opportunity to work with many of you this past year and look forward to working with you in 2026.

Here’s to a great and successful year.