Submission Number: 00007 

Received: 11/29/2012 9:15:07 PM
Commenter:  Fleischmann
Organization: 
State: New York

Agency: Federal Trade Commission
Initiative: Proposed Consent Agreement In the Matter of Hertz Global Holdings, Inc., File No. 101-0137
Attachments: No Attachments
Submission Text
Dear Sir or Madame, I understand that Hertz was recently allowed to purchase Dollar/Thrifty, on condition of divesting their discount Advantage brand, and divesting some Dollar/Thrifty locations at large airports. While it might be assumed this would increase competition, in some instances it actually would not. This is because corporate stores that do one-ways would be replaced with franchises that do not. Ex, If Dollar/Thrifty corporate stores in, say the NYC airports, were accepting a FL driveout, midsize for $1/day beats Hertz's $5/day for a compact. However, if an independent licensee takes over those airports, and a different operator runs each FL station, or all the FL stations, the fleet is no longer interchangeable nationwide, and Hertz becomes the cheapest option. In fact, there'd be less reason for Hertz to stick with the $5/day lowest price point, since Avis and National tend to match each other, starting at $19.95/day. Hopefully this feedback is useful.