Subject: Formal Challenge to Jurisdiction
& Final Notice Before Litigation
Dear
Trip.com, Legal Team,
I
write in response to your latest correspondence, in which you "Wrongly
Assert" that legal proceedings must be conducted under
Singaporean law, citing Trip.com Travel Singapore Pte. Ltd. as the contracting
party.
1. UK Jurisdiction Applies—Your Attempt to Shield
Itself Behind Singaporean Registration Fails
While
Trip.com may "Attempt To Shield Itself" behind a Singaporean entity, it
operates directly through "Trip Air Ticketing (Uk)
Limited,"
a "UK-Registered Company" engaged in travel agency activities and call center
services.
- Company Number: 10811048
- Registered Office: Floor 10,
70 St Mary Axe, London, England, EC3A 8BE
- Nature Of
Business: (SIC 79110 - Travel agency activities & 82200 - Call
centers)
Trip
Air Ticketing (UK) Limited "Exists Solely For UK Operations," enabling Trip.com Group to "Sell
Travel Services Within The UK" while maintaining international headquarters.
The
"Facts Remain Indisputable":
- The transaction
occurred while I was physically in the UK.
- Payment was
made in GBP using a UK-based method.
- Trip.com
actively markets and sells services to UK residents.
Consequently,
"UK Consumer Protection Laws Apply," specifically the "Consumer
Rights Act 2015,"
which "Explicitly Safeguards UK Consumers" against "Deceptive
Business Practices And Service Failures."
Your
"Attempt To Evade Jurisdiction" holds no weight, the "UK Courts
Retain Jurisdiction, Regardless Of Your Registration In Singapore."
2. Your Dismissal of Cost Recovery Is Baseless. The
Evidence Proves Otherwise!
You
have "Arbitrarily Dismissed" my analysis fees under "CPR
46.5," claiming
they are not recoverable. However:
- The "Timestamped
Evidence," consisting of extensive correspondence exchanged over several
months, "Demonstrates The Significant Time And Effort
Invested" in litigating this matter due to Trip.com's "Persistent
Refusal To Engage Properly."
- This "Is
Not A Routine Consumer Complaint" it has involved drafting detailed legal documents,
responding to obstructive procedural objections, and "Compiling
Comprehensive Legal Arguments."
- The structured
communications involved total "[44] Emails And a large
Word Count," further proving the extensive burden caused by Trip.com’s failure
to resolve the matter efficiently.
Under
"CPR 46.5," "Fixed-Rate Cost Recovery" for litigants in
person "Is Explicitly Permitted." My "Calculated Breakdown"
aligns precisely with these guidelines, ensuring "fair compensation for
the effort required due to Trip.com's obstruction tactics."
Furthermore,
compensation "must be adjusted for inflation," given that the
"standard rate was set in 2014" and has not been revised to account
for "the rising cost of living and legal expenses." The
"Cumulative Inflation Rate from 2014 to 2024 Is Approximately 30%,"
meaning the "standard hourly rate of £19 must be adjusted
accordingly."
✅ £19 × 1.30 = £24.70 per hour
This
adjustment ensures that my compensation "reflects real economic impact
rather than outdated figures that no longer hold practical value."
Ignoring inflation would result in "an artificially reduced reimbursement,
failing to account for the devaluation of currency over time." The court
has the discretion to apply "updated rates that align with the financial
reality of litigants in person."
This
precedent protects consumers who "Incur Excessive Burdens Due
To Corporate Negligence," which is the "Core Issue In This
Case."
If you "Dispute The Recovery," then provide "A
Legally Substantiated Reason For Doing So," mere dismissal will not suffice.
3. Misrepresented Airline Documentation—Your
Contradictions Exposed
Your
"Attempt To Obscure The Facts" by falsely attributing my missed
flight to "Travel Documentation Issues" is disproven by "Your
Own Customer Service Records."
At
16/04/2026 05:50pm UTC, EasyJet’s "Customer Service
Advisor Confirmed That Passengers Faced Travel Document Issues," but “EasyJet Refused” to
"Transferred Them To A New Flight At No Cost,"
unlike myself and my travel partner.
However,
you have "Erroneously Conflated My Situation" with that of "Another
Family"
who had an entirely separate issue. This other family was "Denied
Boarding Due To An Expired Passport For One Of Their Child Passengers." In contrast, at 16/04/2026 06:47pm
UTC, I "CORDELL/SIMQN." was separately
verified with a "Valid Passport Issued Just Months
Prior," proving
your attempt to "Wrongly Associate My Case With Theirs."
The
real issue, as "EasyJet’s Records Confirm," was "Trip.com’s
Failure To Generate A Valid Receipt" for my baggage purchase, leading to the financial loss I
incurred:
- At 16/04/2026
06:01pm UTC, EasyJet confirmed that "I Had To
Repurchase A Hold Bag At The Airport," because
Trip.com’s system "Failed To Recognize My Original
Baggage Order," even "Months After" the initial
transaction. Despite my payment being processed and reflected in my
account history, Trip.com's system "Continued To List
The Baggage Order As ‘Processing,’" instead of confirming it as fully paid and valid
for travel.
- This failure "Directly
Resulted In Unnecessary Financial Loss," forcing me to "Pay
Again For The Same Service" due to Trip.com's "Lack Of
Transparency And Functionality."
- Even after
months had passed, your website "Still Displayed My
Baggage Order As Incomplete," a flaw which I documented in my "N1
Claim Form Screenshots."
- At 16/04/2026
06:03pm UTC, EasyJet "Explicitly Confirmed The
Additional Baggage Fee Of GBP 40," reinforcing the direct "Financial
Loss Caused By Your System Failure."
Refusal of insurance documents
Refusal of dedicated case handler
Final Calculations
Your
"Documentation Is Inconsistent And Your Explanations Do Not
Align"
with the factual records. You are "Avoiding
Accountability,"
but the evidence speaks for itself.
4. Final Notice—Litigation Is Imminent
Trip.com’s
responses have been "Marked By Evasion, Misdirection, And
Procedural Stonewalling." You have deliberately "Failed To Engage
Meaningfully"
or acknowledge "Clear Evidence Exposing System Flaws In Your
Receipt Issuance Process."
This
is your "Final Opportunity" to "Resolve This
Dispute Correctly."
If
"Full Compensation And Acknowledgment Of Liability" is not provided "Within
7 Days,"
I will "File My N1 Claim Form With The UK Courts" without further warning.
Failure
to respond with a "Substantive Resolution" will result in "Immediate
Legal Escalation."
Best
regards,
Simon Paul Cordell
|
EasyJet Conversation Transcript Hey, Here's a copy of the conversation you had with us
via web chat. If you have any other questions, please feel free to contact us
again. Thank you! Chat ID: 01%3f9f-2c55-7aaO-b59a-a6c44ceda376 16/04/2025 05:21pm UTC - easy Jet Virtual Advisor: You're now in the queue. Please keep this
conversation and webpage open while we transfer you to one of our Customer
Service advisors. Thank you for your patience. 16/04/2025 05:21pm UTC - easy Jet Virtual Advisor: While you're waiting, make sure you have your ** boo
king reference number** and **passenger information** ready, as we may need
these to locate your booking. 16/04/2025 05:21pm UTC - easyJet Virtual Advisor: For your security, DO NOT attach your payment card information
into this chat. 16/04/2025 05:21pm UTC - easyJet Virtual Advisor: Gif 16/04/2025 05:46pm UTC - easyJet Virtual Advisor: An agent has joined the conversation
16/04/2025 05:46pm UTC - Customer Service Advisor: Welcome to easyJet you are chatting to Saif, could
you please tell me your full name? 16/04/2025 05:46pm UTC - Customer Service Advisor: How may ] assist you? 16/04/2025 05:46pm UTC - You: Hi! This is Shirley from Trip.com. 16/04/2025 06:46pm UTC - You: I just wanted to confirm if the passenger was able
to take the flight under reference K8MSDNZ 16/04/2026 06:47pm UTC - Customer Service Advisor: Hello. Shirley. 16/04/2026 05:47pm UTC ■ Customer Service
Advisor: No worries I will do my best to assist you. Please
tell me the flight time dale route the names of the passengers, and the email
address used on the booking. 16/04/2026 06:47pm UTC - You: CORDELL/SIMQN 16/04/2026 05:46pm UTC - You: One way ■ London-Antalya 16/04/2026 05:46pm UTC - You: 2025-01-08 08:00 LGW/S 15:20 AYT/T2 16/04/2025 05:46pm UTC - You: 16/04/2026 05:45pm UTC ■ Customer Service
Advisor: Thank you. 16/04/2026 05:45pm UTC - Customer Service Advisor: Please allow me 3 minutes to check the booking. 16/04/2026 05:45pm UTC - You: Thank you! 16/04/2026 05:50pm UTC ■ Customer Service
Advisor: My pleasure. 16/04/2026 05:50pm UTC - Customer Service Advisor: Sorry for the wait. I can see that the passengers did face an issue with the travel documents, and we
did transfer them to a new flight for free.
16/04/2026 05:53pm UTC - You: I see. You mean there was an issue with visa
requirements? 16/04/2026 05:53pm UTC - You: Can you also confirm if they did add baggage at the airport? 16/04/2025 05:S5pm UTC * Customer Service Advisor: There was issue with the passengers’ details check from our end and
then we did a free flight transfer
to a new flight “With the Same Luggage Allowance That the Passengers
Had.” 16/04/2025 05:5 Spin UTC - You: Thank you for confirming that. Are you able to confirm
if the added baggage prior to the flight was confirmed? 16/04/2025 05:57pm UTC - Customer Service Advisor: Could you please elaborate on " Are you able to
confirm if the added baggage prior to the flight was confirmed?". 16/04/2025 05:56pm UTC - You: The passenger's initial
issue was related to baggage. They requested to
add carry-on baggage through us before the flight, but at the airport, they were
informed that no baggage had been added. As a result* they had to add baggage
at the airport, and the passenger informed us that they missed the flight due
to this issue. 16/04/2025 05:55pm UTC - You: Can you check and confirm? 16/04/2025 06:0lpm UTC * Customer Service Advisor: You did add a large cabin bag on the 19th of Dec. As
for hold bag allowance as for the hold bag they did indeed purchase a hold bag at the airport 16/04/2025 06:02pm UTC - You: Can you confirm how much is the baggage they added
at the airport? 16/04/2025 06:02pm UTC * Customer Service Advisor: 1 23KG hold bag. 16/04/2025 06:02pm UTC - You: I mean the price of
the baggage. Is it for GBP40? 16/04/2025 06:03pm UTC * Customer Service Advisor Yes 40GBP. 16/04/2025 06:04pm UTC - You: Thank you for confirming. 16/04/2025 06:04pm UTC * Customer Service Advisor: You are always welcome please let me know if there is
anything else I can help you with. 16/04/2025 06:04pm UTC - You:
16/04/2025 06:04pm UTC - Customer Service Advisor: Yes. 16/04/202S 06:04pm UTC - You: And its 15KG carry on. 16/04/2025 06:05pm UTC - Customer Service Advisor: It is a 15KG large cabin bag. 16/04/2025 06:06pm UTC - You: Thank you. Also, to confirm again. The passenger missed
this flight due to an issue with their travel documents, but you were providing
an alternative flight. Right? 16/04/2025 06:06pm UTC ■ Customer Service
Advisor: Yes, that is correct 16/04/2025 06:06pm UTC - Customer Service Advisor: You are always welcome please let me know if there
is anything else I can help you with. 16/04/2025 06:07pm UTC - You: Can you provide the details of the new flight you
provided? 16/04/2025 06:06pm UTC ■ Customer Service
Advisor: Please allow me 3-4 minutes. 16/04/2025 06:06pm UTC - You: Thank you. 16/04/2025 06:06pm UTC - Customer Service Advisor: My pleasure. 16/04/2025 06:12pm UTC ■ Customer Service
Advisor: The new flights were from LTN to AYT at 13:00
arriving at 20:15. The new flights are on the 8th of Jan. 16/04/2025 06:12pm UTC - Customer Service Advisor: Sorry for the wait. 16/04/2025 06:lJpm UTC ■ Customer Service
Advisor: Please reply to me so I can keep the chat up. 16/04/2025 06:13pm UTC ■ Customer Service
Advisor: I can see that you are not responding are you still
connected? 16/04/2025 06:11pm UTC - You: Thank you so much for the information. 16/04/2025 06:14pm UTC - You: Thats all I need. 16/04/2025 06:14pm UTC - Customer Service Advisor: Most welcome and thank you for contacting easyJet,
you were chatting with Saif have a wonderful evening. |
