Comment from Chirag Shah (Executive Vice President for Policy Regulatory and Legal Affairs at the American Hotel and Lodging Association)

Summary: The American Hotel & Lodging Association (AHLA) supports the request for updated guidance but urges the FTC and DOJ to ensure the new guidelines provide clear "safe harbors" for procompetitive practices like revenue management and benchmarking. They argue that current uncertainty has chilled lawful business activities and advocate for definitions that distinguish between dynamic pricing and anticompetitive behavior.