5 unchanged sentences
The COVID-19 pandemic has had and is expected to continue to have a significant adverse impact on our business, including our financial results and prospects, and the travel suppliers on whom our business relies.
−Removed: The spread of COVID-19 and the recent developments surrounding the global pandemic are having significantly negative impacts on all aspects of our business.
−Removed: In response to the pandemic, many governments around the world are implementing a variety of measures to reduce the spread of COVID-19, including travel restrictions and bans, instructions to residents to practice social distancing, quarantine advisories, shelter-in-place orders and required closures of non-essential businesses.
+Added: The spread of COVID-19 and the developments surrounding the global pandemic have had and are continuing to have significantly negative impacts on all aspects of our business.
+Added: In response to the pandemic, many governments around the world have implemented a variety of measures to reduce the spread of COVID-19, including travel restrictions and bans, instructions to residents to practice social distancing, quarantine advisories, shelter-in-place orders and required closures of non-essential businesses.
These government mandates have had a significant negative impact on the travel industry and many of the travel suppliers on whom our business relies, including airlines and hotels, and forced many of them, including airlines, to pursue cost reduction measures and seek financing, including government financing and support, in order to reduce financial distress and continue operating, and to curtail drastically their service offerings.
−Removed: The pandemic has resulted and may continue to result in the restructuring or bankruptcy of certain of those travel suppliers, and renegotiation of the terms of our agreements with them.
+Added: The pandemic has resulted and may continue to result in the restructuring or bankruptcy of certain of those travel suppliers and the renegotiation of the terms of our agreements with them.
The pandemic and these measures have significantly adversely affected, and may further affect, consumer sentiment and discretionary spending patterns, economies and financial markets, and our workforce, operations and customers.
2 unchanged sentences
Our financial results and prospects are largely dependent on these transaction volumes.
−Removed: Although it is impossible to accurately predict the ultimate impact of these developments on our business, our financial results for the year ended December 31, 2020 have been significantly and negatively impacted, with a material decline in total revenues, net income, cash flow from operations and Adjusted EBITDA as compared to 2019.
+Added: Although it is impossible to accurately predict the ultimate impact of these developments on our business, our financial results for the years ended December 31, 2021 and 2020 have been significantly and negatively impacted, with a material decline in total revenues, net income, cash flow from operations and Adjusted EBITDA as compared to 2019.
This downward trend could continue for an unpredictable period.
−Removed: Due to the uncertain and rapidly evolving nature of current conditions around the world, we are unable to predict accurately the impact that COVID-19 will have on our business going forward.
+Added: Due to the uncertain and rapidly evolving nature of current conditions around the world, including the spread of virus variants with new epidemiological characteristics, we are unable to predict accurately the impact that COVID-19 will have on our business going forward.
We expect the outbreak and its effects to continue to have a significant adverse impact on our business, financial condition and operating results for the duration of the pandemic and during the subsequent recovery from the pandemic, which could be an extended period of time.
+Added: To the extent the COVID-19 pandemic adversely affects our business, operations, and financial condition and results, it may also have the effect of heightening many of the other risks described in this "Risk Factors" section, such as those relating to our high level of indebtedness, our need to generate sufficient cash flows to service our indebtedness, and our ability to comply with the covenants contained in the agreements that govern our indebtedness.
The COVID-19 pandemic may result in potential impairments of goodwill, long-term investments and long-lived assets;
12 unchanged sentences
actions taken by national, state and local governments to contain the disease or treat its impact, including travel restrictions and bans, required closures of non-essential businesses, vaccination levels and aid and economic stimulus efforts;
−Removed: the effect of the changes in hiring levels and remote working arrangements that we have implemented on our operations, including the health, productivity, retention, and morale of management and our employees, and our ability to maintain our financial reporting processes and related controls;
+Added: the effect of the changes in hiring levels and remote working arrangements that we have implemented on our operations, including the health,
+Added: productivity, retention, and morale of management and our employees, and our ability to maintain our financial reporting processes and related controls;
the impact on the financial condition on our partners, and any potential restructurings or bankruptcies of our partners;
1 unchanged sentence
our ability to withstand increased cyberattacks;
−Removed: the speed and extent of the recovery across the broader
−Removed: travel ecosystem;
+Added: the speed and extent of the recovery across the broader travel ecosystem;
short- and long-term changes in travel patterns, including business travel;
13 unchanged sentences
Risks Related to Our Business and Industry
+Added: Our ability to recruit, train and retain employees, including our key executive officers and technical employees, is critical to our results of operations and future growth.
+Added: Our continued ability to compete effectively depends on our ability to recruit new employees and retain and motivate existing employees, particularly professionals with experience in our industry, information technology and systems, as well as our key executive officers.
+Added: For example, the specialized skills we require can be difficult and time-consuming to acquire and are often in short supply.
+Added: There is high demand and competition for well-qualified employees on a global basis, such as software engineers, developers and other technology professionals with specialized knowledge in software development, especially expertise in certain programming languages.
+Added: This competition affects both our ability to retain key employees and to hire new ones.
+Added: Similarly, uncertainty in the global political environment may adversely affect our ability to hire and retain key employees.
+Added: Furthermore, the ongoing effects of COVID-19 on our business have adversely affected and may continue to affect our ability to retain key employees and hire new employees.
+Added: See “—The COVID-19 pandemic has had and is expected to continue to have a significant adverse impact on our business, including our financial results and prospects, and the travel suppliers on whom our business relies.” Any of our employees may choose to terminate their employment with us at any time, and a lengthy period of time is required to hire and train replacement employees when such skilled individuals leave the company.
+Added: Furthermore, changes in our employee population, including our executive team, could impact our results of operations and growth.
+Added: For example, we have announced modifications to our business strategies and increased long-term investment in key areas, such as technology infrastructure, that may continue to have a negative impact in the short term due to expected increases in operating expenses and capital expenditures.
+Added: If we fail to attract well-qualified employees or to retain or motivate existing employees, our business could be materially hindered by, for example, a delay in our ability to deliver products and services under contract, bring new products and services to market or respond swiftly to customer demands or new offerings from competitors.
+Added: We operate in highly competitive, evolving markets, and if we do not continue to innovate and evolve, our business operations and competitiveness may be harmed.
+Added: Travel technology is rapidly evolving as travel suppliers seek new or improved means of accessing their customers and increasing value.
+Added: We must continue to innovate and evolve to respond to the changing needs of travel suppliers and meet intense competition.
+Added: We face increasing competition as suppliers seek IT solutions that provide the same traveler experience across all channels of distribution, whether indirectly through the GDS or directly through other channels.
+Added: As travel suppliers adopt innovative solutions that function across channels, our operating results could suffer if we do not foresee the need for new products or services to meet competition either for GDS or for other distribution IT solutions.
+Added: Adapting to new technological and marketplace developments may require substantial expenditures and lead time and we cannot guarantee that projected future increases in business volume will actually materialize.
+Added: We may experience difficulties that could delay or prevent the successful development, marketing and implementation of enhancements, upgrades and additions.
+Added: Moreover, we may fail to maintain, upgrade or introduce new products, services, technologies and systems as quickly as our competitors or in a cost-effective manner.
+Added: For example, we must constantly update our GDS with new capabilities to adapt to the changing technological environment and customer needs.
+Added: However, this process can be costly and time-consuming, and our efforts may not be successful as compared to our competitors.
+Added: Those that we do develop may not achieve acceptance in the marketplace sufficient to generate material revenue or may be rendered obsolete or non-competitive by our competitors’ offerings.
+Added: In addition, our competitors are constantly evolving, including increasing their product and service offerings through organic research and development or through strategic acquisitions.
+Added: As a result, we must continue to invest significant resources in research and development in order to continually improve the speed, accuracy and comprehensiveness of our services and we have made and may in the future be required to make changes to our technology platforms or increase our investment in technology, increase marketing, adjust prices or business models and take other actions, which has affected and in the future could affect our financial performance and liquidity.
+Added: We depend upon the use of sophisticated information technology and systems.
+Added: Our competitiveness and future results depend on our ability to maintain and make timely and cost-effective enhancements, upgrades and additions to our products, services, technologies and systems in response to new technological developments, industry standards and trends and customer requirements.
+Added: As another example, migration of our enterprise applications and platforms to other hosting environments has caused us and will continue to cause us to incur substantial costs, and has resulted in and could in the future result in instability and business interruptions, which could materially harm our business.
+Added: Our Travel Solutions business is exposed to pricing pressure from travel suppliers.
+Added: Travel suppliers continue to look for ways to decrease their costs and to increase their control over distribution.
+Added: For example, consolidation in the airline industry, the growth of LCC/hybrids and macroeconomic factors, among other things, have driven some airlines to negotiate for lower fees during contract renegotiations, thereby exerting increased pricing pressure on our Travel Solutions business, which, in turn, negatively affects our revenues and margins.
+Added: In addition, travel suppliers’ use of multiple distribution channels may also adversely affect our contract renegotiations with these suppliers and negatively impact our revenue.
+Added: For example, as we attempt to renegotiate new GDS agreements with our travel suppliers, they may withhold some or all of their content (fares and associated economic terms) for distribution exclusively through their direct distribution channels (for example, the relevant airline’s website) or offer travelers more attractive terms for content available through those direct channels after their contracts expire.
+Added: As a result of these sources of negotiating pressure, we may have to decrease our prices to retain their business.
+Added: If we are unable to renew our contracts with these travel suppliers on similar economic terms or at all, or if our ability to provide this content is similarly impeded, this would also adversely affect the value of our Travel Solutions business as a marketplace due to our more limited content.
Our revenue is highly dependent on transaction volumes in the global travel industry, particularly air travel transaction volumes.
10 unchanged sentences
(4) political events like acts or threats of terrorism, hostilities, and war;
−Removed: (5) inclement weather, natural or man-made disasters;
+Added: (5) inclement weather, natural or man-made disasters and the effects of climate change;
and (6) factors that affect supply of travel, such as travel restrictions, regulatory actions, aircraft groundings, or changes to regulations governing airlines and the travel industry, like government sanctions that do or would prohibit doing business with certain state-owned travel suppliers, work stoppages or labor unrest at any of the major airlines, hotels or airports.
1 unchanged sentence
See “—The COVID-19 pandemic has had and is expected to continue to have a significant adverse impact on our business, including our financial results and prospects, and the travel suppliers on whom our business relies.”
−Removed: Our Travel Solutions business is exposed to pricing pressure from travel suppliers.
−Removed: Travel suppliers continue to look for ways to decrease their costs and to increase their control over distribution.
−Removed: For example, consolidation in the airline industry, the growth of LCC/hybrids and macroeconomic factors, among other things, have driven some airlines to negotiate for lower fees during contract renegotiations, thereby exerting increased pricing pressure on our Travel Solutions business, which, in turn, negatively affects our revenues and margins.
−Removed: In addition, travel suppliers’ use of multiple distribution channels may also adversely affect our contract renegotiations with these suppliers and negatively impact our revenue.
−Removed: For example, as we attempt to renegotiate new GDS agreements with our travel suppliers, they may withhold some or all of their content (fares and associated economic terms) for distribution exclusively through their direct distribution channels (for example, the relevant airline’s website) or offer travelers more attractive terms for content available through those direct channels after their contracts expire.
−Removed: As a result of these sources of negotiating pressure, we may have to decrease our prices to retain their business.
−Removed: If we are unable to renew our contracts with these travel suppliers on similar economic terms or at all, or if our ability to provide this content is similarly impeded, this would also adversely affect the value of our Travel Solutions business as a marketplace due to our more limited content.
−Removed: Our ability to recruit, train and retain employees, including our key executive officers and technical employees, is critical to our results of operations and future growth.
−Removed: Our continued ability to compete effectively depends on our ability to recruit new employees and retain and motivate existing employees, particularly professionals with experience in our industry, information technology and systems, as well as our key executive officers.
−Removed: For example, the specialized skills we require can be difficult and time-consuming to acquire and are often in short supply.
−Removed: There is high demand and competition for well-qualified employees on a global basis, such as software engineers, developers and other technology professionals with specialized knowledge in software development, especially expertise in certain programming languages.
−Removed: This competition affects both our ability to retain key employees and to hire new ones.
−Removed: Similarly, uncertainty in the global political environment may adversely affect our ability to hire and retain key employees.
−Removed: Furthermore, the ongoing effects of COVID-19 on our business could adversely affect our ability to retain key employees and hire new employees.
−Removed: See “—The COVID-19 pandemic has had and is expected to continue to have a significant adverse impact on our business, including our financial results and prospects, and the travel suppliers on whom our business relies.” Any of our employees may choose to terminate their employment with us at any time, and a lengthy period of time is required to hire and train replacement employees when such skilled individuals leave the company.
−Removed: Furthermore, changes in our employee population, including our executive team, could impact our results of operations and growth.
−Removed: For example, we have announced modifications to our business strategies and increased long-term investment in key areas, such as technology infrastructure, that may continue to have a negative impact in the short term due to expected increases in operating expenses and capital expenditures.
−Removed: If we fail to attract well-qualified employees or to retain or motivate existing employees, our business could be materially hindered by, for example, a delay in our ability to deliver products and services under contract, bring new products and services to market or respond swiftly to customer demands or new offerings from competitors.
Our travel supplier customers may experience financial instability or consolidation, pursue cost reductions, change their distribution model or undergo other changes.
2 unchanged sentences
Adverse changes in any of these relationships or the inability to enter into new relationships could negatively impact the demand for and competitiveness of our travel products and services.
−Removed: For example, a lack of liquidity in the capital markets or weak economic performance, including as a result of the impacts of COVID-19, may cause our travel suppliers to increase the time they take to pay, or to default, on their payment obligations, which could lead to a higher provision for expected credit losses and negatively affect our results.
+Added: For example, a lack of liquidity in the capital markets or weak economic
+Added: performance, including as a result of the impacts of COVID-19, may cause our travel suppliers to increase the time they take to pay, or to default, on their payment obligations, which could lead to a higher provision for expected credit losses and negatively affect our results.
Any large-scale bankruptcy or other insolvency proceeding of an airline or hospitality supplier could subject our agreements with that customer to rejection or early termination, and, if applicable, result in asset impairments which could be significant.
5 unchanged sentences
See "—Our Travel Solutions business is exposed to pricing pressure from travel suppliers."
−Removed: We operate in highly competitive, evolving markets, and if we do not continue to innovate and evolve, our business operations and competitiveness may be harmed.
−Removed: Travel technology is rapidly evolving as travel suppliers seek new or improved means of accessing their customers and increasing value.
−Removed: We must continue to innovate and evolve to respond to the changing needs of travel suppliers and meet intense competition.
−Removed: We face increasing competition as suppliers seek IT solutions that provide the same traveler experience across all channels of distribution, whether indirectly through the GDS or directly through other channels.
−Removed: As travel suppliers adopt innovative solutions that function across channels, our operating results could suffer if we do not foresee the need for new products or services to meet competition either for GDS or for other distribution IT solutions.
−Removed: Adapting to new technological and marketplace developments may require substantial expenditures and lead time and we cannot guarantee that projected future increases in business volume will actually materialize.
−Removed: We may experience difficulties that could delay or prevent the successful development, marketing and implementation of enhancements, upgrades and additions.
−Removed: Moreover, we may fail to maintain, upgrade or introduce new products, services, technologies and systems as quickly as our competitors or in a cost-effective manner.
−Removed: For example, we must constantly update our GDS with new capabilities to adapt to the changing technological environment and customer needs.
−Removed: However, this process can be costly and time-consuming, and our efforts may not be successful as compared to our competitors.
−Removed: Those that we do develop may not achieve acceptance in the marketplace sufficient to generate material revenue or may be rendered obsolete or non-competitive by our competitors’ offerings.
−Removed: In addition, our competitors are constantly evolving, including increasing their product and service offerings through organic research and development or through strategic acquisitions.
−Removed: As a result, we must continue to invest significant resources in research and development in order to continually improve the speed, accuracy and comprehensiveness of our services and we may be required to make changes to our technology platforms or increase our investment in technology, increase marketing, adjust prices or business models and take other actions, which could affect our financial performance and liquidity.
−Removed: We depend upon the use of sophisticated information technology and systems.
−Removed: Our competitiveness and future results depend on our ability to maintain and make timely and cost-effective enhancements, upgrades and additions to our products, services, technologies and systems in response to new technological developments, industry standards and trends and customer requirements.
−Removed: As another example, migration of our enterprise applications and platforms to other hosting environments would cause us to incur substantial costs, and could result in instability and business interruptions, which could materially harm our business.
+Added: Our collection, processing, storage, use and transmission of personal data could give rise to liabilities as a result of governmental regulation, conflicting legal requirements, differing views on data privacy or security incidents.
+Added: We collect, process, store, use and transmit a large volume of personal data on a daily basis, including, for example, to process travel transactions for our customers and to deliver other travel-related products and services.
+Added: Personal data is increasingly subject to legal and regulatory protections around the world, which vary widely in approach and which possibly conflict with one another.
+Added: In recent years, for example, U.S.
+Added: legislators and regulatory agencies, such as the Federal Trade Commission, as well as U.S.
+Added: states, have increased their focus on protecting personal data by law and regulation, and have increased enforcement actions for violations of privacy and data protection requirements.
+Added: The GDPR, a data protection law adopted by the European Commission, went into effect on May 25, 2018, and various other country-specific and U.S.
+Added: state data protection laws have gone into effect or are scheduled to go into effect.
+Added: These and other data protection laws and regulations are intended to protect the privacy and security of personal data, including credit card information that is collected, processed and transmitted in or from the relevant jurisdiction.
+Added: Implementation of and compliance with these laws and regulations may be more costly or take longer than we anticipate, or could otherwise adversely affect our business operations, which could negatively impact our financial position or cash flows.
+Added: Additionally, media coverage of data incidents has escalated, in part because of the increased number of enforcement actions, investigations and lawsuits.
+Added: As this focus and attention on privacy and data protection increases, we also risk exposure to potential liabilities and costs or face reputational risks resulting from the compliance with, or any failure to comply with applicable legal requirements, conflicts among these legal requirements or differences in approaches to privacy and security of travel data.
+Added: Furthermore, various countries, including Russia, have implemented legislation requiring the storage of travel or other personal data locally.
+Added: Our business could be materially adversely affected by our inability, or the inability of our vendors who receive personal data from us, to comply with legal obligations regarding the use of personal data, new data handling or localization requirements that conflict with or negatively impact our business practices.
+Added: In addition, our agreements with customers may also require that we indemnify the customer for liability arising from data incidents under the terms of our agreements with these customers.
+Added: These indemnification obligations could be significant and may exceed the limits of any applicable insurance policy we maintain.
+Added: See “—Security incidents expose us to liability and could damage our reputation and our business.
Implementation of software solutions often involves a significant commitment of resources, and any failure to deliver as promised on a significant implementation could adversely affect our business.
14 unchanged sentences
Although our contracts with larger travel agencies often increase the incentive consideration when the travel agency processes a certain volume or percentage of its bookings through our GDS, travel buyers are not contractually required to book exclusively through our GDS during the contract term.
−Removed: Travel buyers may shift bookings to other distribution channels for many reasons, including to avoid becoming overly dependent on a single source of travel content or to increase their bargaining power with GDS providers.
+Added: Travel buyers also shift bookings to other distribution channels for many reasons, including to avoid becoming overly dependent on a single source of travel content or to increase their bargaining power with GDS providers.
Additionally, some regulations allow travel buyers to terminate their contracts earlier.
13 unchanged sentences
We also typically have three- to five-year contracts with corporate travel departments, which generally renew automatically unless terminated with the required advance notice.
−Removed: A meaningful portion of our travel buyer agreements, typically representing approximately 15% to 20%
−Removed: of our bookings, are up for renewal in any given year.
+Added: A meaningful portion of our travel buyer agreements, typically representing approximately 15% to 20% of our bookings, are up for renewal in any given year.
We cannot guarantee that we will be able to renew our travel buyer agreements in the future on favorable economic terms or at all.
8 unchanged sentences
Because of this concentration among a small number of customers, if an event were to adversely affect one of these customers, it could have a material impact on our business.
−Removed: We are exposed to risks associated with PCI compliance.
+Added: We are exposed to risks associated with payment card industry data (“PCI”) compliance.
The PCI Data Security Standard (“PCI DSS”) is a specific set of comprehensive security standards required by credit card brands for enhancing payment account data security, including but not limited to requirements for security management, policies, procedures, network architecture, and software design.
1 unchanged sentence
The cost of compliance with PCI DSS is significant and may increase as the requirements change.
−Removed: We are tested periodically for assurance and successfully completed our last annual assessment in December 2020.
−Removed: Compliance does not guarantee a completely secure environment and notwithstanding the results of this assessment there can be no assurance that payment card brands will not request further compliance assessments or set forth additional requirements to maintain access to credit card processing services.
−Removed: See “—Security breaches could expose us to liability and damage our reputation and our business.” Compliance is an ongoing effort and the requirements evolve as new threats are identified.
+Added: We are tested periodically for assurance and successfully completed our last annual assessment in November 2021.
+Added: Compliance does not guarantee a completely secure environment and notwithstanding the results of this assessment there can be no assurance
+Added: that payment card brands will not request further compliance assessments or set forth additional requirements to maintain access to credit card processing services.
+Added: See “—Security incidents expose us to liability and could damage our reputation and our business.” Compliance is an ongoing effort and the requirements evolve as new threats are identified.
In the event that we were to lose PCI DSS compliance status (or fail to renew compliance under a future version of the PCI DSS), we could be exposed to increased operating costs, fines and penalties and, in extreme circumstances, may have our credit card processing privileges revoked, which would have a material adverse effect on our business.
−Removed: Our collection, processing, storage, use and transmission of personal data could give rise to liabilities as a result of governmental regulation, conflicting legal requirements, differing views on data privacy or security breaches.
−Removed: We collect, process, store, use and transmit a large volume of personal data on a daily basis, including, for example, to process travel transactions for our customers and to deliver other travel-related products and services.
−Removed: Personal data is increasingly subject to legal and regulatory protections around the world, which vary widely in approach and which possibly conflict with one another.
−Removed: In recent years, for example, U.S.
−Removed: legislators and regulatory agencies, such as the Federal Trade Commission, as well as U.S.
−Removed: states, have increased their focus on protecting personal data by law and regulation, and have increased enforcement actions for violations of privacy and data protection requirements.
−Removed: The GDPR, a data protection law adopted by the European Commission, went into effect on May 25, 2018, the California Consumer Protection Act ("CCPA") went into effect on January 1, 2020, and the California Privacy Rights Act ("CPRA") is scheduled to go into effect on January 1, 2023.
−Removed: These data protection laws and regulations are intended to protect the privacy and security of personal data, including credit card information that is collected, processed and transmitted in or from the relevant jurisdiction.
−Removed: Implementation of and compliance with these laws and regulations may be more costly or take longer than we anticipate, or could otherwise adversely affect our business operations, which could negatively impact our financial position or cash flows.
−Removed: Additionally, media coverage of data breaches has escalated, in part because of the increased number of enforcement actions, investigations and lawsuits.
−Removed: As this focus and attention on privacy and data protection increases, we also risk exposure to potential liabilities and costs or face reputational risks resulting from the compliance with, or any failure to comply with applicable legal requirements, conflicts among these legal requirements or differences in approaches to privacy and security of travel data.
−Removed: Furthermore, various countries, including Russia, have implemented legislation requiring the storage of travel or other personal data locally.
−Removed: Our business could be materially adversely affected by our inability, or the inability of our vendors who receive personal data from us, to comply with legal obligations regarding the use of personal data, new data handling or localization requirements that conflict with or negatively impact our business practices.
−Removed: In addition, our agreements with customers may also require that we indemnify the customer for liability arising from data breaches under the terms of our agreements with these customers.
−Removed: These indemnification obligations could be significant and may exceed the limits of any applicable insurance policy we maintain.
−Removed: See “—Security breaches could expose us to liability and damage our reputation and our business.
We are involved in various legal proceedings which may cause us to incur significant fees, costs and expenses and may result in unfavorable outcomes.
5 unchanged sentences
Other parties might likewise seek to benefit from any unfavorable outcome by threatening to bring or actually bringing their own claims against us on the same or similar grounds or utilizing the litigation to seek more favorable contract terms.
−Removed: In addition, the U.K.
−Removed: Competition and Markets Authority ("CMA") blocked our proposed acquisition of Farelogix, and we have appealed the CMA's decision to the U.K.
−Removed: Competition Appeal Tribunal.
−Removed: We are also subject to a U.S.
−Removed: Department of Justice ("DOJ") antitrust investigation from 2011 relating to the pricing and conduct of the airline distribution industry.
−Removed: We, like other companies in the travel industry, received a civil investigation demand ("CID") from the DOJ and we are fully cooperating.
−Removed: Based on its findings in the investigation, the DOJ may (i) close the file, (ii) seek a consent decree to remedy issues it believes violate the antitrust laws, or (iii) file suit against us for violating the antitrust laws, seeking injunctive relief.
−Removed: In addition, the European Commission’s Directorate-General for Competition ("EC") has opened an investigation to assess whether our and Amadeus’ respective agreements with airlines and travel agents may restrict competition in breach of E.U.
−Removed: antitrust rules.
−Removed: There is no legal deadline for the EC to bring an antitrust investigation to an end, and the duration of the investigation is unknown.
+Added: Additionally and by way of example, on June 29, 2021, American Airlines filed suit against us in state district court in Tarrant County, Texas, alleging that our New Airline Storefront, a modern retailing experience designed to enhance comparison shopping of airline offers in the GDS, and a new value-based incentive model with agencies breach our contract with American Airlines.
+Added: American Airlines sought a temporary and is seeking a permanent injunction preventing the alleged breach of contract.
+Added: We strongly deny the allegations and have filed our response denying American Airlines’ allegations and seeking a declaratory judgment that, among other things, New Airline Storefront does not violate the contract and that the contract does not prohibit Sabre’s value-based fee arrangements.
+Added: In October 2021, the court heard arguments to determine whether to grant a temporary injunction preventing the alleged breach of contract, and on October 27, 2021, the court issued a ruling denying the temporary injunction.
+Added: The Court also denied American Airlines’ subsequent motion seeking reconsideration of the Court’s denial of the temporary injunction.
+Added: If we cannot resolve this matter favorably, we could be limited in our ability to utilize New Airline Storefront and make the value-based incentive payments until our contract with American Airlines terminates.
+Added: Furthermore, if this dispute were to result in the termination of our distribution contract with American Airlines, we may be unable to negotiate a new contract with American Airlines on as favorable terms or at all, which could have a material adverse effect on our business, financial condition and results of operations.
Depending on the outcome of any of these matters, and the scope of the outcome, the manner in which our airline distribution business is operated could be affected and could potentially force changes to the existing airline distribution business model.
26 unchanged sentences
Although regulations specifically governing GDSs have been lifted in the United States, they remain subject to general regulation regarding unfair trade practices by the U.S.
−Removed: Department of Transportation
+Added: Department of Transportation (“DOT”).
In addition, continued regulation of GDSs in the E.U.
10 unchanged sentences
Court of Appeals for the Third Circuit granted the DOJ's motion to vacate the judgment as moot, following the termination of the acquisition agreement as described below.
−Removed: In addition, the CMA has blocked our acquisition of Farelogix.
−Removed: We have appealed the CMA's decision to the U.K.
−Removed: Competition Appeal Tribunal.
+Added: In addition, the U.K.
+Added: Competition and Markets Authority ("CMA") blocked our proposed acquisition of Farelogix, and the U.K.
+Added: Competition Appeal Tribunal has confirmed the CMA’s decision.
Sabre and Farelogix agreed to terminate the acquisition agreement on May 1, 2020 and we paid Farelogix aggregate termination fees of $21 million in the second quarter of 2020 pursuant to the acquisition agreement.
8 unchanged sentences
We have also divested, and may in the future divest, businesses or business operations.
−Removed: Any divestitures may involve a number of risks, including the diversion of management’s attention, significant costs and expenses, the loss of customer relationships and cash flow, and the disruption of the affected business or business operations.
+Added: Any divestitures may involve a number of risks, including the diversion of management’s attention, significant costs and expenses, failure to obtain necessary regulatory approvals, implementation of transition services related to such divestitures, the loss of customer relationships and cash flow, and the disruption of the affected business or business operations.
Failure to timely complete or to consummate a divestiture may negatively affect the valuation of the affected business or business operations or result in restructuring charges.
1 unchanged sentence
We believe that maintaining and expanding our portfolio of product and service brands are important aspects of our efforts to attract and expand our customer base.
−Removed: Our brands may be negatively impacted by, among other things, unreliable service levels from third-party providers, customers’ inability to properly interface their applications with our technology, the loss or unauthorized disclosure of personal data, including payment card industry data ("PCI") or personally identifiable information ("PII"), or other bad publicity due to litigation, regulatory concerns or otherwise relating to our business.
−Removed: See “—Security breaches could expose us to liability and damage our reputation and our business.” Any inability to maintain or enhance awareness of our brands among our existing and target customers could negatively affect our current and future business prospects.
+Added: Our brands may be negatively impacted by, among other things, unreliable service levels from third-party providers, customers’ inability to properly interface their applications with our technology, the loss or unauthorized disclosure of personal data, including PCI or personally identifiable information ("PII"), or other bad publicity due to litigation, regulatory concerns or otherwise relating to our business.
+Added: See “—Security incidents expose us to liability and could damage our reputation and our business.” Any inability to maintain or enhance awareness of our brands among our existing and target customers could negatively affect our current and future business prospects.
We rely on third-party distributor partners and equity method investments to extend our GDS services to certain regions, which exposes us to risks associated with lack of direct management control and potential conflicts of interest.
6 unchanged sentences
Risks Related to Technology and Intellectual Property
+Added: We rely on the availability and performance of information technology services provided by third parties, including DXC and other network, cloud and SaaS providers.
+Added: Our businesses are dependent on IT infrastructure and applications operated for us by DXC and other network, cloud and SaaS providers.
+Added: The commercial services we offer to our customers generally run on infrastructure provided by third parties such as DXC and cloud providers, and DXC provides significant operational support for our mainframe platforms.
+Added: We also use multiple third-party SaaS platforms to operate our services, run our business, and support our customers, including IT service management (ITSM), enterprise resource planning (ERP), customer relationship management (CRM) and human resource information systems (HRIS).
+Added: Our success is dependent on our ability to maintain effective relationships with these third-party technology and service providers.
+Added: Some of our agreements with third-party technology and service providers are terminable for cause on short notice and often provide limited recourse for service interruptions.
+Added: For example, our agreement with DXC provides us with limited indemnification rights.
+Added: We could face significant additional cost or business disruption if:
+Added: • Any of these providers fail to enable us to provide our customers and suppliers with reliable, real-time access to our systems.
+Added: For example, in 2013, we experienced a significant outage of the Sabre platform due to a failure on the part of one of our service providers.
+Added: This outage, which affected our Travel Solutions business, lasted several hours and caused significant problems for our customers.
+Added: Any such future outages could cause damage to our reputation, customer loss and require us to pay compensation to affected customers for which we may not be indemnified or compensated.
+Added: • Our arrangements with such providers are terminated or impaired and we cannot find alternative sources of technology or systems support on commercially reasonable terms or on a timely basis.
+Added: For example, our substantial dependence on DXC for many of our systems makes it difficult for us to switch vendors and makes us more sensitive to changes in DXC's pricing for its services.
Our success depends on maintaining the integrity of our systems and infrastructure, which may suffer from failures, capacity constraints, business interruptions and forces outside of our control.
1 unchanged sentence
Unexpected increases in the volume of our business could exceed system capacity, resulting in service interruptions, outages and delays.
−Removed: These constraints can also lead to the deterioration of our services or impair our ability to process transactions.
+Added: These constraints could also lead to the deterioration of our services or impair our ability to process transactions.
We occasionally experience system interruptions that make certain of our systems unavailable including, but not limited to, our GDS and the services that our Travel Solutions and Hospitality Solutions businesses provide to airlines and hotels.
In addition, we have experienced in the past and may in the future occasionally experience system interruptions as we execute our technology strategy, including our cloud migration and mainframe offload activities.
−Removed: System interruptions prevent us from efficiently providing services to customers or other third parties, causing damage to our reputation and resulting in our losing customers and revenues or causing us to incur litigation and liabilities.
+Added: System interruptions prevent us from efficiently providing services to customers or other third parties, and could cause damage to our reputation and result in the loss of customers and revenues or cause us to incur litigation and liabilities.
Although we have contractually limited our liability for damages caused by outages of our GDS (other than damages caused by our gross negligence or willful misconduct), we cannot guarantee that we will not be subject to lawsuits or other claims for compensation from our customers in connection with such outages for which we may not be indemnified or compensated.
1 unchanged sentence
Much of the computer and communications hardware upon which we depend is located across multiple data center facilities in a single geographic region.
−Removed: Our systems have in the past been and in the future could be damaged or disrupted by events such as power, hardware, software or telecommunication failures, human errors, natural events including floods, hurricanes, fires, winter storms, earthquakes and tornadoes, terrorism, break-ins, hostilities, war or similar events.
−Removed: Computer viruses, malware, denial of service attacks, attacks on hardware or software vulnerabilities, physical or electronic break-ins, cybersecurity incidents or other security breaches, and similar disruptions affecting the Internet, telecommunication services or our systems have caused in the past and could in the future cause service interruptions or the loss of critical data, preventing us from providing timely services.
−Removed: See “—Security breaches could expose us to liability and damage our reputation and our business.” Failure to efficiently provide services to customers or other third parties could cause damage to our reputation and result in the loss of customers and revenues, asset impairments, significant recovery costs or litigation and liabilities.
+Added: Our systems have in the past been and at any time, including in the future, could be damaged or disrupted by events such as power, hardware, software or telecommunication failures, human errors, natural events including floods, hurricanes, fires, winter storms, earthquakes and tornadoes, terrorism, break-ins, hostilities, war or similar events.
+Added: Computer viruses, malware, denial of service attacks, ransomware attacks, attacks on, or exploitations of, hardware or software vulnerabilities, physical or electronic break-ins, phishing attacks, cybersecurity incidents or other security incidents, and similar disruptions affecting the Internet, telecommunication services or our systems have caused in the past and could at any time, including in the future, cause service interruptions or the loss of critical data, preventing us from providing timely services.
+Added: For example, in April 2021 our subsidiary Radixx announced an event impacting its Radixx reservation system.
+Added: See “—Security incidents expose us to liability and could damage our reputation and our business.” Failure to efficiently provide services to customers or other third parties could cause damage to our reputation and result in the loss of customers and revenues, asset impairments, significant recovery costs or
+Added: litigation and liabilities.
Moreover, such risks are likely to increase as we expand our business and as the tools and techniques involved become more sophisticated.
3 unchanged sentences
Customers and other end-users who rely on our software products and services, including our SaaS and hosted offerings, for applications that are integral to their businesses may have a greater sensitivity to product errors and security vulnerabilities than customers for software products generally.
−Removed: Additionally, security breaches that affect third parties upon which we rely, such as travel suppliers, may further expose us to negative publicity, possible liability or regulatory penalties.
+Added: Additionally, security incidents that affect third parties upon which we rely, such as travel suppliers, may further expose us to negative publicity, possible liability or regulatory penalties.
Events outside our control could cause interruptions in our IT systems, which could have a material adverse effect on our business operations and harm our reputation.
−Removed: Security breaches could expose us to liability and damage our reputation and our business.
−Removed: We process, store, and transmit large amounts of data, including PII and PCI of our customers, and it is critical to our business strategy that our facilities and infrastructure, including those provided by DXC Technology ("DXC") or other vendors, remain secure and are perceived by the marketplace to be secure.
+Added: Security incidents expose us to liability and could damage our reputation and our business.
+Added: We process, store, and transmit large amounts of data, including PII and PCI of our customers, and it is critical to our business strategy that our facilities and infrastructure, including those provided by DXC Technology ("DXC"), cloud providers or other vendors, remain secure and are perceived by the marketplace to be secure.
Our infrastructure may be vulnerable to physical or electronic break-ins, computer viruses, or similar disruptive problems.
2 unchanged sentences
To address these threats and intrusions, we have a team of experienced security experts and support from firms that specialize in data security and cybersecurity.
−Removed: We are periodically subject to these threats and intrusions, and sensitive or material information has in the past been, and could in the future be, compromised as a result.
+Added: We are periodically subject to these threats and intrusions, and sensitive information has in the past been, and could at any time, including in the future be, compromised as a result.
The costs of investigation of such incidents, as well as remediation related to these incidents, may be material.
3 unchanged sentences
Commitments and Contingencies, to our consolidated financial statements for additional information.
−Removed: The costs related to these incidents, including any additional associated penalties assessed by any other governmental authority or payment card brand or indemnification obligations to our customers, as well as any other impacts or remediation related to them, may be material.
−Removed: Any computer viruses, malware, denial of service attacks, ransomware attacks, on hardware or software vulnerabilities, physical or electronic break-ins, cybersecurity incidents, such as the items described above, or other security breach or compromise of the information handled by us or our service providers may jeopardize the security or integrity of information in our computer systems and networks or those of our customers and cause significant interruptions in our and our customers’ operations.
−Removed: Any systems and processes that we have developed that are designed to protect customer information and prevent data loss and other security breaches cannot provide absolute security.
+Added: In addition, in April 2021, our subsidiary, Radixx, announced that it had experienced an event that impacted its Radixx Res™ reservation system.
+Added: An investigation indicated that malware on the Radixx Res™ reservation system caused the activity.
+Added: Based on the investigation, Sabre’s systems, including GDS, Airline IT, SabreSonic passenger service system and Hospitality Solutions systems, were not impacted, and the investigation indicated that the Radixx database containing customer information was not compromised in this event.
+Added: The costs related to these incidents, including any additional associated penalties assessed by any other governmental authority or payment card brand or indemnification or other contractual obligations to our customers, as well as any other impacts or remediation related to them, may be material.
+Added: Any computer viruses, malware, denial of service attacks, ransomware attacks, attacks on, or exploitations of, hardware or software vulnerabilities, physical or electronic break-ins, phishing attacks, cybersecurity incidents, such as the items described above, or other security incident or compromise of the information handled by us or our service providers may jeopardize the security or integrity of information in our computer systems and networks or those of our customers and cause significant interruptions in our and our customers’ operations.
+Added: Any systems and processes that we have developed that are designed to protect customer information and prevent data loss and other security incidents cannot provide absolute security.
In addition, we may not successfully implement remediation plans to address all potential exposures.
It is possible that we may have to expend additional financial and other resources to address these problems.
−Removed: Failure to prevent or mitigate data loss or other security breaches could expose us or our customers to a risk of loss or misuse of such information, cause customers to lose confidence in our data protection measures, damage our reputation, adversely affect our operating results or result in litigation or potential liability for us.
+Added: Failure to prevent or mitigate data loss or other security incidents could expose us or our customers to a risk of loss or misuse of such information, cause customers to lose confidence in our data protection measures, damage our reputation, adversely affect our operating results or result in litigation or potential liability for us.
While we maintain insurance coverage that may, subject to policy terms and conditions, cover certain aspects of cyber risks, this insurance coverage is subject to a retention amount and may not be applicable to a particular incident or otherwise may be insufficient to cover all our losses beyond any retention.
1 unchanged sentence
The implementation of these investments may be more costly or take longer than we anticipate, or could otherwise adversely affect our business operations, which could negatively impact our financial position, results of operations or cash flows.
−Removed: We rely on the availability and performance of information technology services provided by third parties, including DXC, which manages a significant portion of our systems.
−Removed: Our businesses are largely dependent on the computer data centers and network systems operated for us by DXC, and its third-party providers, including AT&T, to which DXC outsources certain network services.
−Removed: We also rely on other developers and service providers to maintain and support our global telecommunications infrastructure, including to connect our computer data center and call centers to end-users.
−Removed: Moreover, we outsourced our global enterprise resource planning system to a third-party provider, and any disruption to that outsourced system may negatively impact our business.
−Removed: Our success is dependent on our ability to maintain effective relationships with these third-party technology and service providers.
−Removed: Some of our agreements with third-party technology and service providers are terminable for cause on short notice and often provide limited recourse for service interruptions.
−Removed: For example, our agreement with DXC provides us with limited indemnification rights.
−Removed: We could face significant additional cost or business disruption if:
−Removed: • Any of these providers fail to enable us to provide our customers and suppliers with reliable, real-time access to our systems.
−Removed: For example, in 2013, we experienced a significant outage of the Sabre platform due to a failure on the part of one of our service providers.
−Removed: This outage, which affected our Travel Solutions business, lasted several hours and caused significant problems for our customers.
−Removed: Any such future outages could cause damage to our reputation, customer loss and require us to pay compensation to affected customers for which we may not be indemnified or compensated.
−Removed: • Our arrangements with such providers are terminated or impaired and we cannot find alternative sources of technology or systems support on commercially reasonable terms or on a timely basis.
−Removed: For example, our substantial dependence on DXC for many of our systems makes it difficult for us to switch vendors and makes us more sensitive to changes in DXC's pricing for its services.
Intellectual property infringement actions against us could be costly and time consuming to defend and may result in business harm if we are unsuccessful in our defense
Third parties may assert, including by means of counterclaims against us as a result of the assertion of our intellectual property rights, that our products, services or technology, or the operation of our business, violate their intellectual property rights.
−Removed: We are currently subject to such assertions, including patent infringement claims, and may be subject to such assertions in the future.
+Added: We are currently subject to such assertions, including patent infringement claims, and may be subject to such assertions
+Added: in the future.
These assertions may also be made against our customers who may seek indemnification from us.
8 unchanged sentences
Even if we are not held liable, we may choose to settle claims by making a monetary payment or by granting a license to intellectual property rights that we otherwise would not license.
−Removed: Further, judgments may result in loss of reputation, may force us to take costly remediation actions, delay selling our products and offering our services, reduce
−Removed: features or functionality in our services or products, or cease such activities altogether.
+Added: Further, judgments may result in loss of reputation, may force us to take costly remediation actions, delay selling our products and offering our services, reduce features or functionality in our services or products, or cease such activities altogether.
Insurance may not cover or be insufficient for any such claim.
23 unchanged sentences
These licensors may breach or otherwise fail to perform their obligations or claim that we have breached or otherwise attempt to terminate their license agreements with us.
−Removed: We also rely on license agreements to allow third parties to use our intellectual property rights, including our software, but there is no guarantee that our licensees will abide by the terms of our license agreements or that the terms of our agreements will always be enforceable.
+Added: We also rely on license agreements to allow third parties to use our intellectual property rights, including our software, but there is no guarantee that our licensees will abide by the terms of our license agreements or that the terms of our agreements will always be
In addition, policing unauthorized use of and enforcing intellectual property can be difficult and expensive.
9 unchanged sentences
Some open source licenses contain requirements that we make available source code for modifications or derivative works we create based upon the open source software and that we license these modifications or derivative works under the terms of a particular open source license or other license granting third parties certain rights of further use.
−Removed: If we combine or, in some cases, link our proprietary software solutions with or to open source software in a certain manner, we could, under certain of the open source licenses, be required to release the source code of our proprietary
−Removed: software solutions or license such proprietary solutions under the terms of a particular open source license or other license granting third parties certain rights of further use.
+Added: If we combine or, in some cases, link our proprietary software solutions with or to open source software in a certain manner, we could, under certain of the open source licenses, be required to release the source code of our proprietary software solutions or license such proprietary solutions under the terms of a particular open source license or other license granting third parties certain rights of further use.
In addition to risks related to license requirements, usage of open source software can lead to greater risks than use of third-party commercial software, as open source licensors generally do not provide warranties or controls on origin of the software.
6 unchanged sentences
Our geographic concentration in the United States and Europe, as well as our expanded focus in APAC, makes our business potentially vulnerable to economic and political conditions that adversely affect business and leisure travel originating in or traveling to these regions.
−Removed: The COVID-19 outbreak has significantly and negatively impacted the global economy, including increased unemployment, reduced financial capacity of both business and leisure travelers, diminished liquidity and credit availability, declines in consumer confidence and discretionary income and general uncertainty about economic stability.
+Added: The COVID-19 outbreak has significantly and negatively impacted the global economy, including increased unemployment, inflation and supply constraints, reduced financial capacity of both business and leisure travelers, diminished liquidity and credit availability, declines in consumer confidence and discretionary income and general uncertainty about economic stability.
Furthermore, recent changes in the U.S.
5 unchanged sentences
These adverse economic conditions may negatively impact our business results in those regions.
−Removed: Voters in the U.K.
−Removed: have approved the exit of that country from the E.U.
−Removed: (“Brexit”), which became effective as of January 31, 2020, and was in a transition period through December 31, 2020.
+Added: has exited from the E.U.
Brexit and related processes have created significant economic uncertainty in the U.K.
and in EMEA, which may negatively impact our business results in those regions.
−Removed: In addition, the terms of the U.K.’s withdrawal from the E.U., once negotiated during the transition period, if at all, could potentially disrupt the markets we serve and the tax jurisdictions in which we operate and adversely change tax benefits or liabilities in these or other jurisdictions, including our ability to obtain Value Added Tax ("VAT") refunds on transactions between the U.K.
+Added: In addition, the terms of the U.K.’s withdrawal from the E.U.
+Added: could potentially disrupt the markets we serve and the tax jurisdictions in which we operate and adversely change tax benefits or liabilities in these or other jurisdictions, including our ability to obtain Value Added Tax ("VAT") refunds on transactions between the U.K.
and the E.U., and may cause us to lose customers, suppliers, and employees.
51 unchanged sentences
These covenants may limit our ability to effectively operate our businesses or maximize stockholder value.
−Removed: In addition, our Amended and Restated Credit Agreement requires that we meet certain financial tests, including the maintenance of a leverage ratio and a minimum net worth, as well as maintain certain minimum liquidity levels during any covenant suspension resulting from a "Material Travel Event Disruption." See Liquidity and Capital Resources.
−Removed: Our ability to satisfy these tests may be affected by factors and events beyond our control, and we may be unable to meet such tests in the future.
Any failure to comply with the restrictions of our Amended and Restated Credit Agreement or any agreement governing our other indebtedness may result in an event of default under those agreements.
18 unchanged sentences
Depending on the size of the exposures and the relative movements of interest rates, if we choose not to hedge or fail to effectively hedge our exposure, we could experience a material adverse effect on our results of operations and financial condition.
−Removed: As of December 31, 2020, we had outstanding approximately $2.8 billion of variable debt that is indexed to the London Interbank Offered Rate ("LIBOR").
−Removed: It is not possible to predict the effect of any changes in the methods by which LIBOR is determined or regulatory activity related to LIBOR’s phaseout.
−Removed: Any of these developments could cause LIBOR to perform differently than in the past or cease to exist.
−Removed: If a published U.S.
−Removed: dollar LIBOR rate is unavailable, the interest rates on our debt indexed to LIBOR will be determined using various alternative methods set forth in our Amended and Restated Credit Agreement, any of which could result in interest obligations that are more than or that do not otherwise correlate over time with the payments that would have been made on this debt if U.S.
−Removed: dollar LIBOR were available in its current form.
−Removed: Any of these proposals or consequences could have a material adverse effect on our financing costs.
−Removed: Moreover, our interest rate swap agreements designated in a hedging relationship utilize one-month LIBOR and have maturities that extend through 2021.
−Removed: Derivatives, to our consolidated financial statements.
+Added: As of December 31, 2021, we had outstanding approximately $2.8 billion of variable debt that is indexed to the London Interbank Offered Rate ("LIBOR") consisting of Term Loan B for $1.8 billion, Term Loan B-1 for $401 million and Term Loan B-2 for $635 million.
+Added: In July 2017, the Financial Conduct Authority announced its intention to phase out the London Interbank Offered Rate ("LIBOR") by the end of 2021, and subsequently extended the phase-out date to June 30, 2023.
+Added: See " Management's Discussion and Analysis of Financial Condition and Results of Operations —Liquidity and Capital Resources—Senior Secured Credit Facilities" for the estimated impacts of this change.
+Added: We intend to seek an amendment with our lenders of Term Loan B prior to June 2023 to provide for a transition to the Secured Overnight Financing Rate ("SOFR") or another alternative to LIBOR in anticipation of its discontinuation, but there can be no assurance that we will be able to reach an agreement with our lenders for any such amendment or that the incremental amount of any interest pursuant to such amendment would be significantly less than current requirements.
The market price of our common stock could decline due to the large number of outstanding shares of our common stock eligible for future sale.
35 unchanged sentences
Because we operate globally, the nature of the uncertain tax positions is often very complex and subject to change, and the amounts at issue can be substantial.
−Removed: It is inherently difficult and subjective to estimate such amounts, as we have to determine the probability of various possible outcomes.
+Added: It is inherently difficult and subjective to estimate such amounts, as we must determine the probability of various possible outcomes.
We re-evaluate uncertain tax positions on a quarterly basis.
3 unchanged sentences
Such changes could result in an increase or decrease in the effective tax rate applicable to all or a portion of our income or losses which would impact our profitability.
−Removed: We consider the undistributed capital investments in our foreign subsidiaries to be indefinitely reinvested as of December 31, 2020 and, accordingly, have not provided deferred taxes on any outside basis differences.
+Added: We consider the undistributed capital investments in our foreign subsidiaries to be indefinitely reinvested as of December 31, 2021, and, accordingly, have not provided deferred taxes on any outside basis differences for most subsidiaries.
+Added: With respect to our AirCentre portfolio of products, we have set up deferred taxes, where applicable, for the outside basis of the capital investment of subsidiaries to be sold.
We establish reserves for our potential liability for U.S.
−Removed: taxes, including sales, occupancy and VAT, consistent with applicable accounting principles and in light of all current facts and circumstances.
+Added: taxes, including sales, occupancy, and VAT, consistent with applicable accounting principles and considering all current facts and circumstances.
We also establish reserves when required relating to the collection of refunds related to value-added taxes, which are subject to audit and collection risks in various countries.
6 unchanged sentences
Several countries, primarily in Europe, and the European Commission have proposed or adopted taxes on revenue earned by multinational corporations in certain "digital economy" sectors from activities linked to the user-based activity of their residents.
−Removed: These proposals have generally been
−Removed: labeled as "digital services taxes" ("DSTs").
+Added: These proposals have generally been labeled as "digital services taxes" ("DSTs").
We continue to evaluate the potential effects that the DST may have on our operations, cash flows and results of operations.
25 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.