News, Opinions on Recent SkyMiles Changes

Have SkyMiles Program Changes Failed Delta's Best Customers and Shareholders?

By Ari Royce Magedoff
September 2003

In December 2002, Delta Air Lines made one of the boldest moves in the airline industry since the September 11th attacks. In an unprecedented attempt to streamline its business, Delta became the only airline to change the way in which frequent flyer credits are earned. The change brought a great outcry from its most prestigious members, the SkyMiles Medallion members. The outcry from these customers led to a rededication of a website created after Delta's first changes in its program in the mid 1990's, www.saveskymiles.com, and the launch of a protest at the airline's annual shareholders' meeting in New York City. Since the changes went into effect, little has been done by the airline to address the issues of the customers it affected most. This lack of response and lack of inquiry by the airline before the proposed changes led to the development of this article. The area of corporate governance has grown exponentially in the last several years. This article will explore how the development of these changes has failed the best customers of Delta and failed the shareholders of the company the board represents.

Airline Industry Pre-Deregulation

Prior to the deregulation of the airline industry in 1978, it was overseen by the government-based Civil Aviation Board (CAB). The focus of CAB was to regulate the industry as a whole. This regulation included the all facets of the airline industry. CAB was responsible for assigning routes and landing rights in all U.S. airports. CAB controlled the prices that could be charged for tickets on a particular route. In addition, the market was limited to what the CAB would allow. Entrance was restricted to what the CAB felt was necessary. International routes, as well as international presence in the United States was heavily restricted and monitored by the CAB. One major airline, Pan American, controlled almost all of the U.S.-based international flight traffic. This allegedly occurred because of a close relationship between a former CAB chairman and Pan American. The industry as a whole did not provide much flexibility to customers and prices were heavily controlled and monitored. The ticket price availability present in today's market did not exist prior to 1978. The only real benefit from this time period was that the major carriers were required to serve small and less profitable cities. In order to maintain lucrative routes, the CAB required the majors to service these less opportunistic routes.

Airline Deregulation Act of 1978

In response to requests among the airlines, Congress passed the Airline Deregulation Act of 1978. The Act focused on turning control of the airlines over to the airlines themselves. This meant that airlines could negotiate new routes with airports and transit authorities, set their own ticket prices and policies, drop low profit and smaller cities, and expand into international opportunities once monopolized by Pan American. The CAB was sunsetted by the Act.

Concurrent with the Act was the birth of the hub system. Prior to the Act, airlines operated on a point-to-point system. This system is very similar to the one flown by low-fare carriers today, most notably Southwest Airlines. The airlines had an extensive network that consisted largely of flying people between city pairs. This provided fewer opportunities for passengers and forced the majors to incur great costs. The result was the birth of the hub and spoke airline system. Just as a wheel is centered and the spokes protrude from the center, the airline industry felt this type of traffic system would bring in the greatest profits. The five major carriers, American, Delta, Eastern, Pan American, and United, selected "hub cities'' in which to base their operations. American Airlines chose Dallas, Delta chose Atlanta, Eastern chose Miami, United chose Chicago-O'Hare, and Pan American chose New York. From these points, each airline could hit major cities and minor cities across the U.S. Instead of having to fill a plane with, for example, passengers from Los Angeles to Washington, D.C., a major carrier could now fly all Los Angeles-based passengers to Atlanta and then to whatever city they desired on the eastern seaboard. The cost reduction to the airlines was phenomenal. The first couple of years after the Act saw the greatest airline profits recorded up until that time for most of the majors, except Pan American, which was hit by the opening of international routes to the other majors.\1/

The Birth of the Frequent Flyer Program

The short period following deregulation did produce profits for the airlines, but soon the airlines were faced with a difficult problem. The question that circulated through airline board meetings and executive management meetings was how to gain customers and keep them flying with their respective airline. Many of the airlines had similar service and similar pricing. American Airlines' advertising firm, Doyle Dane Bernbach, created the first program concept, in which the carrier would reward its best customers with certain perks, such as a free first class ticket and companion ticket to Hawaii or discounted fares. As American was devising its program, Western Air Lines came out with its own version. The Travel Pass program awarded $50 certificates to passengers who flew five trips on Western. American in mid-1980 unveiled its program, called A'Advantage. United, which had developed a program earlier and shelved it, quickly released its Mileage Plus frequent flyer program. By the early 1980's, every major airline, including Delta, had created a frequent flyer program.\2/

Delta's Frequent Flyer Program

In 1981, Delta launched its frequent flyer program, known as Delta Frequent Flyer. The program met with great success, as did all the frequent flyer programs of the time. Customers quickly joined and aligned themselves with their airline of choice. The program continued to succeed with random changes occurring here and there. Then, in 1994, the original Delta Frequent Flyer program was announced defunct and the airline decided to align itself with the programs of the other majors.\3/ The new program was met with great opposition from Delta's then-Medallion level flyers. In response to a May 9, 1994 article, seventy-two frequent flyers called into Christopher McGinnis of the Atlanta Journal Constitution to voice their complaints over the new program. Then-Royal Medallion member Garret Kirkland stated, "I've complained to Delta, and they seem tired of hearing about it.''\4/ However, Delta did respond by making some upgrade concessions to their best flyers, but the old program would be gone and SkyMiles was the future of Delta and its frequent flyers.\5/

The Corporate Governance Paradigm

Corporate governance has been defined as the relationship among various participants in determining the direction and performance of the corporation.\6/ There are three primary participants in the corporate governance paradigm: the directors, the management, and the shareholders. Another significant group within the paradigm, but not established as a primary participant, are the customers of a corporation.\7/ The American Law Institute, in its 1992 proposed final draft of Principles of Corporate Governance declared that the "corporation should have as its objective the conduct of business activities with a view to enhancing corporate profit and shareholder gain.''\8/ The corporate governance paradigm, growing exponentially due to a rash of scandals across corporate America, presents a particularly difficult problem for corporate managers and directors. The problem consists of how to maintain a corporation upholding the governance virtues during a recession and maximize profits and shareholder gain without prejudicing the customer base with the cuts required to maximize profits. According to Robert Monks, the key to solving corporate governance issues, such as the problem noted above, is balancing the interests by finding the right system of checks and balances.\9/ In the words of Ralph Cordinier, a long-time CEO of General Electric Company, top management is a "trustee'' responsible for managing the enterprise "in the best interest of shareholders, customers, employees ._._._.''\10/ This article will now apply the corporate governance paradigm to the recent changes made in the Delta SkyMiles program and how it is effecting both the customer entity and the shareholder entity, and whether the program changes are a balanced interest for all the parties involved.

The Recent 2002-2003 Delta SkyMiles Changes

In December 2002, Delta Air Lines announced a drastic change to its then-existing SkyMiles program. Since 1994 and 2000, Delta had not made such drastic changes to the way mileage status would be determined. In 1994, Delta's Frequent Flyer program was changed to SkyMiles. With that change came a backlash from the carrier's best customers, the then-Medallion and Royal Medallion flyers. The backlash resulted in a compromise between the two groups, allowing members to keep their old program miles and utilize them on the old award and upgrade chart. All new mileage would be earned under SkyMiles.\11/ SkyMiles began to flourish and membership increased. It seemed as if Delta weathered its first storm. Then in 2000, Delta announced changes once again. These changes would restrict the types of fares that could be upgraded and would eliminate the distribution and accrual of general system-wide upgrades. Once again, Delta was met with backlash from its best customers, then known as Silver, Gold, and Platinum Medallion elite members. This time, a small group of disgruntled Medallion members formed a website to express their anger and hoped to influence Delta to rescind the changes. saveskymiles.com was born, along with an apparently new-found distrust for the carrier that was once heralded as an airline with a cutting edge and flyer-friendly frequent flyer program. Delta did not rescind and the changes and restrictions remained in place. The new restricted upgrade fares, L and U fares, became known as "LUser'' fares among the elite flyers. Some people jumped ship, but many stayed as the economy was riding high and businesses could afford to send their employees on the slightly higher fares.

2003 Key Changes Made To The SkyMiles Program

Delta's key changes to its SkyMiles program are centered on the earning of elite status. Previously, actual miles flown and segments flown would determine the earning of status in the airline's SkyMiles program. The new program does not allow earning status by segments flown, removing base miles from the determination, and basing elite status on "Medallion qualification miles'' (mqm). A Medallion qualification mile is determined based on the mileage flown and the type of ticket purchased. First class fares qualify for double mqm's, while a deep discounted ticket will get half mqm's. The program rewards Delta's highest paying customers and not necessarily the customers who spend the most annually at the airline. The program rewards on a per-flight basis. In addition, the program reduced the unlimited upgrades to the highest elite flyers and changed the amount of upgrades that could be earned by the mid- and low-tier elite flyers. The 800-mile segment upgrade was reduced to a 500-mile segment upgrade. The amount of upgrades given was also drastically reduced to the members of the Medallion program. The changes do permit companions to be upgraded with mile segment upgrades. North American Medallion Upgrades, another perk of the program for the mid- and low-tier members, were discontinued under the new program.\12/

How Delta Is Losing Its Best Customers

The post-September 11, 2001 airline industry realized huge losses. Early retirements, furloughs, and terminations were required by almost every major airline to stay afloat. Delta continued to struggle but avoided bankruptcy. In an effort to maintain the airline, CEO Leo Mullin ordered cuts across the company. These included reductions in meal service, changes to onboard compliments like silverware, and other basic reductions, including even the discontinuation of the airline's paper schedules. The largest and most controversial cutback would be in the way Delta's SkyMiles' members would earn elite status. Delta considers the move a call to reward those who invest the most in the airline by rewarding higher-paying passengers with qualification miles based on the value of the ticket purchased, as opposed to simply the number of miles flown.

The changes to the SkyMiles program came on the heel of one of the company's greatest economic losses since its inception. Recognizing a $2.1 billion loss to the carrier for fiscal year 2002, Delta SkyMiles program director Rob Borden believes the move will create more revenue for the airline. The belief is that business flyers, those who traditionally pay more for a ticket,\13/ will continue to pay high fares in an attempt to maintain status on the airline. However, the new program lacks qualification based on segments. Many of the platinum Medallion members, especially those who reside in Atlanta and the Southeast, qualified based on short haul regional flights. These hundred-plus segment flyers are also some of Delta's best customers. These passengers, many earning the 500-mile minimum, are now alienated under the new program. This type of flyer, the segment flyer, can easily average fifty roundtrips per year at the minimum. If we assume the average regional ticket costs, at a minimum, $200 and is approximately 400 miles in length, based on the old program, these were high revenue flyers for Delta. Why are they no longer being rewarded? This group, of the many apparently feeling alienated by this program, probably has the most to squawk about. Delta's Borden sees the new program rewarding those who invest the most, and even stated that many people have told the airline that the new program is fairer.\14/ Apparently, it seems, Borden has figured out a way to alienate an entire group of travelers investing a lot in the health of Delta's bottom line. Yet he still is sticking by his new program. Borden and the entire Delta management team, even after a meeting with several Delta flyers,\15/ a protest at the shareholders meeting, the distribution of "saveskymiles'' pins, and the rebirth of the "saveskymiles'' website, continue to believe that the program is moving in the right direction.

On any given day of the week, two events are guaranteed. The first is that any member of the public can visit Randy Petersen's www.flyertalk.com website and find a number of ongoing posts on people's dissatisfaction with the changes in the SkyMiles program. The second is that on www.saveskymiles.com thousands of miles are being added to the protest against the changes to SkyMiles. As of September 2003, over 3.2 billion miles have been logged in to protest to the changes made by Delta.\16/

The numbers seem to speak for themselves. A lot of people are upset, and the airline continues to march on, believing it will weather this storm, as it did the first storm when www.saveskymiles.com was begun after the introduction of L and U fares. However, the defections apparently have already begun. Numerous Medallion flyers have either taken all of their business away from Delta or will do so once they do not re-qualify for their status.\17/ But based on a recent move by Delta, we will not know entirely how many people actually lose status with the airline. Soon after the changes to the program were announced and went into affect, Delta announced that those who do not re-qualify for 2004 will only lose one tier of status for the next year.\18/ This guarantees Delta a healthy program for 2004 showing very little drop off, except for the coveted Platinum Medallion level that will show the actual effects of the changes. But even that may not become apparent for some time. Numerous PMs, as they are known on flyertalk.com, continue to fly because the perks of the original program remain in effect until 2004. The actual drop-off of these flyers will not be seen until next year when either they drop down to Gold status or leave the airline as PMs because the benefit of unlimited upgrades will be discontinued.

Delta might already be feeling the effect of the changes and reactions by its passengers. The airline reported that traffic, as measured by revenue passenger miles, fell three percent in the month of August 2003.\19/ In the recent government report that measures domestic passenger volume, Southwest Airlines became the first discount carrier to carry more passengers than any traditional carrier in a month period. In May, Southwest carried over 200,000 more passengers than the traditional monthly leader, Delta. Delta has been the nationwide leader the past several years in passengers carried, but ranks third in revenue passenger miles.\20/ There is no statistical evidence that this change in position resulted from disgruntled Delta frequent flyers moving to another airline. But it does show a trend in the industry that the traditional carriers, who continue to reduce perks and the ways in which they reward their best customers, no longer separate themselves from the discount carriers. The problem now is that passengers, most notably frequent flyers, who would once pay more to receive the benefits of a traditional carrier, for example first class upgrades and frequent flyer miles, no longer are using those factors as traditional carriers are no more a bargain than the discount carriers. Discount carriers will continue to grow and traditional carriers, like Delta, will continue to retreat in their numbers as they continue to reduce the programs that drew business travelers to their airlines. It is expected that, by 2006 or 2007, Southwest will easily be the number one airline in all categories.\21/

How Delta Is Failing Its Shareholders

The possibility that a discount carrier will be number one in all categories of airline grading should have Delta and other mainline carriers scrambling back to the drawing board, as they did in 1980 and 1981, to find an innovative way to bring customers to their airlines. It should be a time of creative strategy and cutting edge marketing to reclaim the passengers lost to the discount carriers. Instead, Delta has given its best passengers every reason not to fly the airline and, in the end, this will hurt their bottom line and, in turn, their shareholders.

As noted supra, corporate governance requires a corporation to make decisions that maximize profits and shareholder gain. Based on recent numbers by Delta, the airline seemly is not maximizing any profits and is not making decisions that will affect future shareholder gain. Instead, the airline lost 1.3 billion dollars\22/ and has implemented a new program that apparently will drive its best and highest-revenue customers to other airlines.

Delta has a standard corporate governance policy set forth on its website. The basic document outlines board functions, board structure, and board operations. A quick review of this document will relay that the words "customer,'' "profits,'' or even "gain'' are not mentioned. The word "shareowner'' is mentioned once and is used in the description of director compensation, stating it shall align the interest of the board with those of the common stock shareowners.\23/ The traditional board duties are outlined and include the review of the one-year business plan that should have included the recent changes to the SkyMiles program. Based on its implementation, the board approved these changes. However, this leaves little room for shareholder legal action.

Shareholders reserve the right to voice their opinion at the annual shareholders meeting or by selling their stock. However, in response to a recent attempt to inform the shareholders of the changes and the unhappiness of the highest revenue customers, Delta management restricted the distribution of saveskymiles flyers at the annual shareholder meeting. Shareholders of Delta, and also members of the "saveskymiles'' group, were restricted from informing shareholders of the changes and the unhappiness of this group. Instead, they were asked to either remove themselves or refrain from distributing such information.\24/ However, the protest was not without some success. A rolling billboard circled the meeting outside New York's Plaza Hotel in an effort to call shareholders' attention to the changes they felt were being made to the company. The attempt, however, was overshadowed by the then-recent release of information concerning Delta executive compensation.

The Delta executive compensation packages could not have come at a worse time for the airline. Just as the shareholders meeting was weeks away, the story broke about the compensation, bonus, and pension packages being given to the Delta executives. The determination by Delta board to grant such packages to their executives appeared to show a complete disregard for any form of corporate governance. The airline lost approximately 1.3 billion dollars in 2002 and was in line for the greatest bail-out check from the United States taxpayers, approximately $422 million.\25/ Not only would Delta have to answer to its shareholders, but it would be viewed by the public as a company taking hundreds of millions of dollars of taxpayers' money and padding executive paychecks, giving millions in bonuses and setting up bankruptcy-proof "golden'' pension plans.

At a time when the industry was seeing record lows, and Delta also experienced record lows in both profit and stock price, its management seemingly was rewarded to keep the team together. Chief Executive Officer Leo Mullin received approximately $13 million in compensation, including bonuses, for 2002, allegedly for keeping his airline out of bankruptcy and minimizing losses to $1.3 billion. A CEO should not be rewarded for keeping a company out of bankruptcy and minimizing losses when it is the job of the CEO to lead the company out of turmoil with innovative ideas that make the company a leader in the industry. Instead, Mullin used the traditional method of downsizing to minimize losses. Employees were terminated and cuts were made across the airline, as noted supra. The airline might have reduced losses but, at the same time, it created programs to drive customers away. It is a frightening and risky way to run a business and is a great risk that will only burden the shareholders of Delta. With executives in bankruptcy-proof pensions, the fate of the company will not effect them.\26/ The only group bearing the real risk is the shareholders. This is a blatant disregard to the corporate governance paradigm and to Delta's own corporate governance policies.

In addition, the pension choice made by the Delta board is one that is rarely used, especially in the airline industry. The secular trust, designed to guarantee the executive pensions, requires payments and taxes to be paid upfront.\27/ The secular trust, used by only 10 of the Fortune 1000 companies, is rarely used because it costs the company approximately 60 percent more than other plans. The most alluring part, at least to Delta executives, is that creditors cannot reach the trust if Delta files for bankruptcy. However, in order to fund this trust, Delta was required to put $25.5 million up front, with millions more required for payment in 2003.\28/ With a $1.3 billion loss on the books, and accepting $422 in taxpayer funds, it is impossible to justify such a decision to expend the extra cash as the company cuts both employees and customer benefits. It is a decision that fails everyone. It fails the shareholders, the employees, the customers, and the public trying to keep the airline industry intact. The only winners are the executives and the board they answer to.

Based on the Smith v. Van Gorkum decision, a presumption exists "that in making a business decision, the directors of a corporation act on an informed basis, in good faith and in the honest belief that the action taken was in the best interests of the company.''\29/ The Delta shareholders would have a hard time overcoming this standard. The shareholders' best possible determination in a lawsuit against the board would be to show that the Delta board failed to make an informed decision. This would require a very strict review of internal board documents and a thorough review of the board's minutes. However, the standard leaves the Delta board in a very good position to continue to make these decisions.

Legal Action by the Frequent Flyers

Delta makes it explicitly clear in its SkyMiles Rules and Conditions under the subsection Important Notice Concerning Program Changes and Termination that Delta and its program partners reserve the "right to change program rules, benefits, regulations, Travel Awards, fees, mileage Award levels and special offers at any time without notice. This means that Delta may initiate changes, for instance, impacting partner affiliations; rules for earning mileage credit . . . .''\30/ In 1995, the most high profile frequent flyer case was argued in front of the Supreme Court. In American Airlines v. Wolens, the plaintiffs sued American Airlines for changes that retroactively restricted the frequent flyer miles they had previously earned. The suit commenced in Illinois in 1992 and the Illinois court ruled that American could not retroactively change the frequent flyer program. The Supreme Court remanded the case, citing Morales v. Trans World Airlines, in which language in the Airline Deregulation Act of 1978 was cited. The Morales court cited language in the ADA forbidding state laws "having the force and effect of law relating to rates, routes, or services of any air carrier.''\31/ The case was remanded to be decided applying the aforementioned section of the act.\32/

Upon remand, the Illinois court found a loophole in the Act. The loophole states that "the claims at issue do not relate to the rates, routes, or services of an airline and a frequent flyer program is not an essential element to the operation of an airline.'' Therefore, "a contractual relationship is formed which vests the frequent flyer with the right to earn specific awards.''\33/ The decision in Wolens placed an important limitation on the airlines that would restrict them from making retroactive changes and established the rights of frequent flyers.

Delta's recent SkyMiles program changes did not make any retroactive changes except for altering the then-existing 800-mile segment upgrades to 500-mile segment upgrades. Beginning in 2003, Delta changed the program and changed all available 800-mile segment upgrades to 500-mile segment upgrades by multiplying the existing 800s by 1.6. Therefore, five 800 msu's would become eight 500 msu's under the new program. However, there is a flaw in this determination that retroactively reduces the value of the previous earned segment upgrades under the old program. Under the old program, for a flight from Fort Lauderdale to Atlanta, a Medallion level flyer could use one 800 msu to upgrade a flight. The flight, which is 581 aeronautical miles, would require two 500 msu's to upgrade the flight under the new program. If a Medallion flyer had five 800 msu's, the flyer could upgrade five flight segments between Fort Lauderdale and Atlanta in the old program. However, under the new program, those five 800 msu's, converted to eight 500 msu's, allows that same frequent flyer to upgrade only four segments between Fort Lauderdale and Atlanta. Under the old program, prior to 2003, Delta distributed the mile segment upgrades based on mileage flown and re-qualification of elite status. On mileage flown, a silver Medallion member who flew 10,000 base miles would earn four msu's and a gold Medallion would earn 8 on the same base mileage. Platinum Medallions were given unlimited msu's under the old program.

Mileage segment upgrades are similar to general frequent flyer awards. Msu's, like awards, are given based on miles. Both are capacity controlled and restricted by the airline. Based on the changes made by Delta, the airline appears vulnerable to lawsuit based on the decision in Wolens. Delta's modifications made retroactive changes to msu's already earned. The question now is what can be done by the carrier's frequent flyers.

The most likely option would be a class action suit against the airline. A long, drawn-out, and extremely costly case could be expected. Delta could reconsider the changes, not only based on the legal arguments, but also on the issues previously discussed in this article. If a lawsuit was brought, would the Delta contractual restrictions preclude any case on part of the plaintiffs? A possible route for the frequent flyers could be in the realm of equity.

A suit in equity, as opposed to one in law, is a determination solely made by the court. It is not guaranteed and is only available where there is no adequate legal remedy.\34/ Generally, a court will only grant relief where a property right is present, but some courts require only a protectable interest. Membership in a frequent flyer program could be considered a protectable interest. If the frequent flyers of Delta were to bring a suit in equity, the following is a brief synopsis of what would have to be done by the plaintiffs to be successful.

Equitable relief offers several different methods of seeking a remedy. The most notable in issues of contract enforcement, as would be used in a case of a frequent flyer against an airline, would be specific performance. To prove specific performance, a plaintiff must established six grounds: (1) a contract exists; (2) all contractual conditions have been fulfilled; (3) the legal remedy is inadequate; (4) enforcement is feasible; (5) mutuality of remedy exists; and (6) there are no defenses available to the defendant.\35/

A contract exists between Delta and its frequent flyers based on the entrance requirement of the program. The issuance of the frequent flyer number is indicative of this contractual relationship. The frequent flyer members, by abiding by the rules and flying the airline by presenting their frequent flyer numbers before a flight, have fulfilled the contractual conditions of the program. Delta is then required to post the earned miles to a frequent flyer member's account. The issue is whether the frequent flyers can force Delta to enforce the previous Delta SkyMiles program under the theory of specific performance.

Since a contract exists and the contractual conditions have been fulfilled by the frequent flyers, it must be shown that a legal remedy is inadequate. With over 32 million SkyMiles members and monetary damages being the sole legal remedy, the most efficient remedy in an action such as this would not be monetary but an equitable remedy in the form of either additional miles, upgrades, or a return to the old program, hence enforcing the original SkyMiles membership contract before the new program took effect. Enforcement of these remedies would be quite feasible, as it would require Delta to enforce the program that it successfully enforced for approximately 8 years. Therefore, mutuality of remedy exists as both frequent flyers and Delta could fulfill their contractual obligations under the old program. There are no known defenses available to Delta that would restrict enforcement under specific performance.

Under this proposed theory of enforcement, Delta's frequent flyers could seek relief in a return to the old program, a granting of mileage credit, or a grandfather clause to allow all old program benefits to be used under old program rules until those benefits have been completely utilized by the frequent flyers. This type of equitable determination would continue the increased frequent flyer rights first established by the Wolens court.

Conclusion

Delta Air Lines has failed to make decisions that insure that its best customers will remain loyal to its program. The program it established to lure both business and leisure travelers is currently the same redesigned program driving these customers away. Both the decision to change the SkyMiles program and recent determinations by the Delta board have failed the carrier's shareholders as well. Under the corporate governance paradigm, Delta should redesign its own corporate governance policies and enforcement procedures to insure its successful survival through the difficult times facing the airline industry.

Ari Royce Magedoff is a graduate of Seattle University School of Law, where he studied corporate law. During law school, Mr. Magedoff served as Student Bar Association President and Vice President and sat on the law school's budget committee. Prior to law school, Mr. Magedoff attended the University of Miami where he graduated cum laude, with general university honors, and departmental honors in political science. Mr. Magedoff currently resides in New York City where he passed the New York bar examination in July and is beginning his career as a lawyer.

- Delta Air Lines, The Plane Truth http://www.delta.com/pdfs/plane_truth.pdf
- Randy Petersen, It Was 20 Years Ago Today, www.webflyer.com (May 2001)
- Christopher McGinnis, Delta's New Frequent-Flyer Program Helps Create a "Common Currency," The Atlanta Journal Constitution E8 (April 18, 1994)
- Christopher McGinnis, Frequent Flyers Voice Their Complaints About New Delta SkyMiles Program, The Atlanta Journal Constitution E4 (May 9, 1994)
- Christopher McGinnis, Delta Tries to Calm Frequent Flyers, Reveals Upgrade Plan For Most Loyal, The Atlanta Journal Constitution E7 (July 18, 1994)
- Robert Monks, Corporate Governance, Blackwell Publishing, 2001 (1)
- Monks (1)
- Monks (23)
- Monks (36)
- Monks (36-37)
- Christopher McGinnis, Frequent Flyers Voice Their Complaints About New Delta SkyMiles Program, The Atlanta Journal Constitution E4 (May 9, 1994)
- www.delta.com
- Delta Air Lines, The Plane Truth http://www.delta.com/pdfs/plane_truth.pdf
- James Pilcher, Angry Delta Consumers Aim to Increase Pressure, The Cincinnati Enquirer (April 9, 2003)
- James Pilcher, Angry Delta Consumers Aim to Increase Pressure, The Cincinnati Enquirer (April 9, 2003)
- www.saveskymies.com
- www.flyertalk.com, Delta Forum
- Delta letter to Medallion level flyers.
- Staff Report, Delta Ridership down, but Subsidiaries' Grow, The Atlanta-Journal Constitution (September 4, 2003)
- Staff Report, Southwest Overtakes Delta in Passengers, The Atlanta-Journal Constitution (August 13, 2003)
- Staff Report, Southwest Overtakes Delta in Passengers, The Atlanta-Journal Constitution (August 13, 2003)
- Russell Grantham, Pinched Delta Gives Bonuses to Execs Last Year, The Atlanta-Journal Constitution (March 26, 2003)
- Delta Corporate Governance Principles www.delta.com
- www.flyertalk.com, Delta Forum
- Russell Grantham, Delta in Line for Biggest Federal Bailout Check, The Atlanta-Journal Constitution (April 16, 2003)
- Robert Luke, Delta Execs' Pension Choice Rarely Used, The Atlanta-Journal Constitution (April 4, 2003)
- Robert Luke, Delta Execs' Pension Choice Rarely Used, The Atlanta-Journal Constitution (April 4, 2003)
- Robert Luke, Delta Execs' Pension Choice Rarely Used, The Atlanta-Journal Constitution (April 4, 2003)
- Smith v. Van Gorkum, 488 A. 2d 858 (Del. Supr. 1985)
- www.delta.com, Skymiles Membership Rules & Conditions
- 49 U.S.C. sec. 1305(a)(l) (1988)
- American Airlines v.Wolens, 513 US 219 (1995)
- http://www.lib.niu.edu/ipo/ii940233.html
- http://www.pvamu.edu/edir/wvetter/law-equity-contract.htm
- Laclede Gas Co. v. Amoco Oil Co., 522 F.2d 33 (1975)


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