This blog is intended to house commentary on a variety of subjects related primarily, but not exclusively, to consumer issues, national and local political issues and other random matters to which I believe I have something to say that may be of interest to readers. If you are so inclined, please leave a comment. If not, that’s fine too. This blog consists entirely of opinions, which are solely those of the author. My background is set out below.
I (Paul M. Ruden) graduated from Yale University with a Bachelor of Arts cum laude degree and earned a J.D. degree from the Harvard Law School. Through my legal career I was a member of the District of Columbia Bar and the Virginia Bar.
My career began as a Trial Attorney at the Civil Aeronautics Board (“CAB”). After entering private practice, I focused on the field of aviation regulation while serving as managing partner of my law firm. My law practice was focused on representing aviation and other travel businesses actually or potentially subject to regulation by the CAB and, later, the U.S. Department of Transportation (“DOT”).
I was retained to represent the American Society of Travel Agents (“ASTA”), the largest trade association of travel agents in the world, for the final deregulation case directed at the travel agency‑airline relationship, the Investigation into the Competitive Marketing of Air Transportation, CAB Docket 36595, Order 82-12-85, December 17, 1982, aff’d Republic Airlines, Inc. v. C.A.B., 756 F.2d 1304 (8th Cir. 1985). I later joined the ASTA staff as Senior Vice President, Legal, Industry & Government Affairs. My responsibilities included all of ASTA’s internal and external legal activities, industry policy issues, state and federal legislation, consumer affairs and extensive media activity. I was the senior advisor to the chief staff officer, the Board of Directors and all affiliates and subunits of the association. I served twice as Acting Chief Operating Officer.
In my capacity as ASTA’s chief legal advisor, I wrote numerous pleadings in formal rulemakings and from time to time authored amicus curiae briefs in various courts related to the issue of taxation of retail markups on the sale of hotel accommodations by online and offline travel agencies. I also taught numerous travel industry related seminars at various ASTA meetings and was a speaker at numerous industry events, including programs of the American Bar Association Forum on Air and Space Law.
While working at ASTA I authored “Competition in the Distribution of Travel Services — The Future of Travel Agents,” an economic manuscript published for industry use by ASTA, and authored and edited the two editions of the ASTA Travel Agent Manual. I also wrote “Distribution Dilemmas”, in the Handbook of Airline Marketing, McGraw-Hill (1998), “Competitive Issues Arising from the Orbitz Joint Venture,” in Air & Space Lawyer, American Bar Association (Spring, 2001) and “The Travel Agency Perspective: Ancillary Service Transactability Will Benefit Consumers and Competition,” Air & Space Lawyer, American Bar Association (November 3, 2014), among other articles.
The Speaker of the House of Representatives appointed me one of the nine commissioners of the National Commission to Ensure Consumer Information and Choice in the Airline Industry, whose report to Congress was issued November 13, 2002. I also served on the Department of Transportation’s Air Carrier On-time Reporting Advisory Committee, and, by appointment of the Secretary of Transportation, was a member of the DOT National Task Force to Develop Model Contingency Plans to Deal with Lengthy Airline On-Board Ground Delays (aka the Tarmac Delay Task Force). Through my career at ASTA, I testified multiple times before various Congressional committees on a range of industry issues.
I retired from ASTA as Executive Vice President for Legal & Industry Affairs as of October 1, 2015 and in January 2016 began writing a monthly column for the online publication Travel Market Report. ASTA named an industry “Travel Ambassador” award in my name for presentation to an individual who has made significant contributions to the welfare of the travel agency industry.