INDEX / DIRECTORY / EXPEDIA / DIGITAL

Expedia DIGITAL

DIGITAL INFRASTRUCTURE AUDIT UPDATED 2026-10-28
Digital Score 6.90 /10 B Expedia - Complicity Index 768
Digital 6.90

Evidence-only forensic audit. Scoring happens downstream - see the main dossier for the composite assessment.

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Target: Expedia Group, Inc. (Expedia) Research date: 26 October 2026 Domain: Digital Evidence period: Historical disclosures through October 2026

Enterprise Technology Stack & Vendor Relationships

Corporate identity and integrated entities

Expedia Group, Inc. is a Delaware-incorporated, publicly traded travel-technology company whose 2025 Form 10-K describes consumer travel platforms, business-to-business distribution and technology-supported travel services.1

Its significant disclosed subsidiaries at 31 December 2025 included Expedia, Inc.; Hotels.com L.P.; HomeAway.com, Inc.; Travelscape, LLC; Interactive Affiliate Network, LLC; EG Corporate Travel Holdings LLC; Cruise, LLC; Expedia Treasury US, LLC; Expedia.com Limited; Expedia Lodging Partner Services Sàrl; and Expedia Treasury Services Limited.2

Expedia, Inc. identifies itself as operator of the Expedia UK website, through which customers enter travel-service contracts with relevant providers; the legal notice separately identifies Travelscape LLC as an Expedia Travel contracting entity.3

Israeli-origin technology integration: Guesty

Guesty’s corporate history records that it established its headquarters in Tel Aviv in 2014, identifying an Israeli corporate and operational origin for the accommodation-management technology platform.4

Guesty identifies itself as an Expedia Group Preferred Connectivity Partner and documents integration with Expedia and Vrbo for accommodation distribution, reservation management and related property-management functions.5

Guesty’s Expedia connection instructions require the accommodation operator to select Guesty as its property-management/connectivity provider within Expedia Partner Central and then connect existing listings to its Guesty account.6

The documented relationship therefore involves Guesty supplying accommodation connectivity technology to participating property managers, with Expedia receiving or exchanging property-distribution information through that interface; the page is published on help.guesty.com, dates of individual commercial agreements are not disclosed, and the integration remained publicly documented when reviewed on 26 October 2026.6

Guesty describes a broader property-management product covering booking channels, reservations, guest communications, payments and operational workflows, although its public material does not disclose which of these modules Expedia itself purchases, if any.5

No public evidence identified establishing direct Expedia enterprise licensing of Guesty, mandatory group-wide use of Guesty, the revenue attributable to Expedia-connected bookings or the physical processing location of Expedia-linked information within Guesty’s infrastructure.

Technology partner programme

Expedia Group’s Certified Technology Partners Programme enables third-party providers to integrate with its Rapid API, with Elite and Preferred classifications based on integration performance and technical capabilities.7

Expedia states that participation in this programme does not require every partner to use an intermediary and that technology-partner selection remains a commercial decision for the participating business.7

This programme provides a documented third-party technical distribution channel; the Expedia-hosted description does not identify compulsory deployment of Israeli-origin security or analytics products.7

Enterprise cloud services

In November 2017 [pre-2020], Amazon Web Services, Inc. announced that Expedia, Inc. was migrating significant core-business workloads, digital properties, mobile applications and databases from company-owned infrastructure to AWS.8

The announcement also identified AWS machine-learning technology and database migration involving Microsoft SQL Server, Oracle and Amazon Aurora, with enterprise infrastructure and digital travel services as the intended applications.8

The acting technology supplier was AWS, the beneficiary was Expedia, Inc., and the announcement appeared on press.aboutamazon.com on 29 November 2017; the original migration represented a substantial enterprise infrastructure programme, while the current deployment footprint and specific Israeli cloud-region use remain unverified.8

Microsoft distribution technology

On 29 October 2024, Expedia Group, Inc. and Microsoft Corporation announced a Bing travel-booking and loyalty partnership involving Expedia-powered accommodation bookings and Microsoft Rewards.9

The identified channel was the Microsoft Bing platform, serving users booking eligible accommodation; the original announcement appeared on ir.expediagroup.com, with an initial dated observation of 29 October 2024 and no independently verified termination date.9

Other named Israeli-origin enterprise vendors

No public evidence identified of Expedia Group, Inc. directly procuring Check Point, Wiz, SentinelOne, CyberArk, NICE, Verint, Claroty, Palo Alto Networks or comparable Israeli-origin enterprise security products.

No public evidence identified that Expedia’s named systems integrators mandated Israeli-origin security software for its corporate systems.

No public evidence identified of a group-wide enterprise dependency on Israeli-origin cybersecurity or business analytics technology.

Surveillance, Biometrics & Retail Technology

Facial recognition and identity technologies

On 19 May 2026, Expedia Group announced a partnership with CLEAR intended to improve travel experiences through airport-security and identity-related services for Expedia travellers and One Key members.10

The acting parties were Expedia Group and CLEAR, the intended beneficiaries were eligible travellers, and the announcement appeared on ir.expediagroup.com; the partnership was announced in May 2026, while its complete deployment timetable and subsequent termination status were not established.10

The Expedia announcement does not establish that this arrangement uses biometric software from Trigo, BriefCam, AnyVision/Oosto, Trax or another Israeli-origin vendor.10

No public evidence identified of Expedia independently deploying Israeli-origin facial recognition, gait analysis, retail surveillance or biometric identification systems.

Behavioural and commercial analytics

Expedia’s July 2026 B2B privacy statement describes processing information for user authentication, booking, account management, platform security and service operations.11

The statement also describes personal-information processing associated with services and automated or AI-supported functions, without identifying an Israeli-origin surveillance vendor as the operator of these systems.11

No public evidence identified of Expedia using Israeli-origin predictive-policing, workforce surveillance, social-media monitoring or law-enforcement analytics products.

Indirect third-party deployment

Guesty’s Expedia connectivity documentation establishes a third-party route for accommodation information to interact with Expedia’s platform; this is a property-distribution and management integration rather than evidence of deployment of an Israeli surveillance product.6

No public evidence identified establishing Israeli-origin facial-recognition or behavioural-surveillance software bundled into Expedia’s enterprise technology by a third-party managed service provider.

Cloud Infrastructure, Data Residency & Sovereign Cloud Participation

Platform infrastructure and data residency

Expedia’s consumer privacy statement identifies servers located in the United States and states that affiliated companies, employees and third-party providers may access or process personal information internationally.12

Its international-transfer policy separately states that the company uses US-based servers and transfers personal data to relevant affiliates and third parties where necessary to operate its travel business.12

The Expedia B2B privacy statement, last updated on 7 July 2026, identifies booking information, user identity information, accounts and commercial transactions among its processing activities.11

This establishes the collection and routing of personal information through a multinational travel-services network; it does not identify a specific Expedia-owned Israeli data centre, Israeli hosting region or Israeli sovereign-cloud environment.11

No public evidence identified establishing that Expedia Group operates, leases or co-locates data-centre infrastructure in Israel.

Potential third-party data flows

Guesty describes software that manages property listings, reservations, guest communication and payments, while its Expedia documentation describes technical links between participating property managers and Expedia listings.5

These documents establish technological interoperability with an Israeli-origin supplier but do not specify whether particular Expedia-linked personal-data records are stored or processed in Israel.6

No public evidence identified establishing the actual physical residency, database region or Israeli-jurisdiction access pathway for Expedia-linked records handled through Guesty.

Government cloud programmes

No public evidence identified of Expedia Group, Inc., Expedia, Inc., Hotels.com L.P. or Vrbo participating as a named provider or contractor in Project Nimbus.

No public evidence identified of Expedia providing sovereign cloud services, data-residency infrastructure or resilience infrastructure to Israeli state institutions.

No public evidence identified of an Expedia contract to host Israeli military or intelligence data.

Technology dependency and attribution

AWS publicly documented a substantial Expedia cloud migration in 2017 [pre-2020]; that announcement does not establish the deployment of Expedia workloads in AWS’s Israeli infrastructure or participation by Expedia in any Israeli government cloud contract.8

Defence, Intelligence & Security Sector Technology Relationships

Direct state and military contracts

No public evidence identified of a direct technology contract between Expedia Group, Inc. or its named subsidiaries and the Israel Ministry of Defence, Israel Defense Forces, Israeli intelligence agencies or Israeli national-security bodies.

No public evidence identified of Expedia supplying communications monitoring, military databases, surveillance analytics or military-specific cloud hosting services to those bodies.

General-purpose technology provision

Expedia Group announced in May 2026 that its B2B platform serves approximately 75,000 partners across industries and 200,000 travel advisers, with an estimated 21 billion API calls daily based on internal 2025 data.13

The acting entity was Expedia Group’s B2B division, the beneficiaries were commercial distribution partners, and the reported capabilities covered travel inventory, pricing, reservations, payments and AI-assisted distribution; the announcement was published on ir.expediagroup.com on 20 May 2026.13

The publicly described technology is general-purpose commercial travel infrastructure, and the announcement does not identify an Israeli military, intelligence or security organisation as an API customer.13

No public evidence identified of a named Israeli military user deploying Expedia’s APIs for operational military purposes.

Settlement-related digital services

Amnesty International documented in January 2019 [pre-2020] that Expedia.com and Hotels.com carried accommodation listings in Israeli settlements in the occupied West Bank and East Jerusalem.14

In July 2025, independent reporting identified further Expedia, Hotels.com and Vrbo accommodation listings located in settlements in the West Bank, occupied East Jerusalem and the Golan Heights.15

The documented digital service comprises search, accommodation advertising, booking availability and travel distribution rather than military-specific technology; Expedia Group is the platform operator, accommodation providers and travellers are the commercial counterparties, and property-level contracting entities and transaction values are not established in these reports.15

Offensive cyber and military targeting

No public evidence identified of Expedia developing, licensing, supplying or maintaining offensive cyber tools, zero-day exploitation systems or military digital weapons.

No public evidence identified of Expedia supplying software purpose-built for autonomous targeting, fire-control decisions or kinetic military effects.

AI, Algorithmic & Autonomous Systems

Consumer and B2B AI systems

On 14 May 2025, Expedia Group announced Expedia Trip Matching, an AI-based travel discovery feature, alongside Hotels.com’s AI Agent and integrations with OpenAI Operator and Microsoft Copilot Actions.16

The acting entity was Expedia Group, the commercial beneficiaries were travellers and distribution partners, and the channels included Expedia and Hotels.com products, OpenAI Operator and Microsoft Copilot Actions; the corporate announcement appeared on ir.expediagroup.com.16

The disclosed functions included converting travel-related social content into trip recommendations, conversational shopping, booking assistance and contextual servicing; continued operation of each specific integration as of October 2026 was not separately verified.16

On 20 May 2026, Expedia Group B2B introduced plans for an Intelligent Experience Platform comprising AI components intended to support partners building travel-shopping and booking experiences.13

The corporate announcement stated that the toolkit was in development, with deployment to selected partners anticipated; therefore, the announcement establishes planned commercial functionality rather than complete deployment to all partners.13

AI-enabled identity and travel experiences

At its May 2026 Explore conference, Expedia Group described additional AI-powered trip planning and travel-support features, together with its announced CLEAR partnership.10

The disclosed commercial applications concerned travel planning, booking support and airport passenger experience; no Israeli military AI customer was identified in the announcement.10

Training data and access

Expedia’s B2B privacy statement describes processing information to enable booking, account management, security and service functionality, including the use of AI-related systems.11

No public evidence identified of Expedia training AI systems on intercepted communications, Israeli intelligence datasets or surveillance-derived datasets from occupied Palestinian territory.

No public evidence identified of Expedia providing Israeli state security bodies with access to traveller-derived AI training datasets.

Autonomous systems

No public evidence identified of Expedia supplying autonomous threat-detection, target-generation, tracking or weapons-control systems to Israeli military or intelligence agencies.

On 30 July 2024, trivago N.V., a publicly traded hotel-search company controlled by Expedia Group, acquired an initial equity interest in Holisto Limited, an Israeli AI-driven travel-technology company specialising in hotel-rate aggregation and white-label booking engines. trivago’s 2025 Form 20-F records an initial investment of €10.2 million for a 38.6% ownership interest, equivalent to 30.0% on a fully diluted basis, together with an option to acquire the remaining shares. Expedia Group held 59.2% of trivago’s equity and 83.9% of its voting power at 31 December 2025, establishing that the investment and subsequent acquisition occurred within an Expedia-controlled corporate group.17

On 31 July 2025, trivago completed its acquisition of Holisto by purchasing the remaining outstanding equity interests for approximately €22.3 million (US$25.5 million). Its contemporaneous SEC Form 6-K confirms that Holisto became a wholly owned and consolidated subsidiary and that trivago would operate Holisto’s existing business, including its merchant-of-record activities for hotel bookings. The filing identifies Holisto as an AI-driven hotel-rate aggregator and white-label booking-engine provider employing 211 people across its headquarters in Israel and other international locations. Holisto was subsequently renamed trivago DEALS Ltd., establishing the completed acquisition of an Israeli-headquartered technology business and its operating capabilities by an Expedia-controlled subsidiary.18, 17

trivago’s 2025 Form 20-F confirms that the acquired technology was integrated into its commercial booking strategy. The filing describes trivago Book & Go as functionality enabling travellers to complete bookings directly within trivago’s platform without being redirected to third-party booking websites. It explicitly identifies integration with trivago DEALS as accelerating this booking functionality and enabling advertising partners to use a trivago-branded booking funnel intended to improve conversion rates and competitiveness. The disclosed functionality and integration establish operational adoption of the acquired Israeli-origin booking technology, although the filing does not quantify the proportion of bookings processed through Holisto’s systems or establish deployment across every trivago advertising partner.17

The acquisition also created a consolidated commercial and technology-development relationship. trivago’s 2025 financial disclosures identify €5.3 million of related-party revenue from Holisto before consolidation during 2025, compared with €3.0 million in 2024, primarily comprising click-through fees. They separately identify interface-development expenses of €0.6 million in 2025 and €0.2 million in 2024 before consolidation. These figures provide evidence of commercial integration and technical interface-development activity preceding full ownership, while the subsequent consolidation means they cannot be interpreted as continuing independent vendor payments after acquisition.17

trivago N.V.’s primary SEC filings establish a two-stage acquisition of Holisto Limited. On 30 July 2024, trivago acquired a 38.6% equity interest (30.0% fully diluted) for €10.2 million and obtained an option to acquire the remaining shares. On 31 July 2025, it exercised that option and acquired the remaining 69.2% equity interests for €22.3 million (US$25.5 million). The difference between the original 38.6% holding and the 30.8% interest immediately before completion reflects intervening share-option exercises. Holisto consequently became a wholly owned, consolidated subsidiary, subsequently renamed trivago DEALS Ltd. trivago’s contemporaneous Form 6-K identifies Holisto’s headquarters in Israel, its 211 employees across Israel and other international locations, and its hotel-rate aggregation, white-label booking-engine and merchant-of-record operations. The 2025 Form 20-F confirms Expedia Group’s controlling interest in trivago of 59.2% of equity and 83.9% of voting power at 31 December 2025. These filings confirm the audit’s existing 2024 investment and 2025 completed-acquisition statements. They also establish that an Expedia-controlled subsidiary acquired and consolidated an Israeli-headquartered operating technology business. This qualifies the Economic statement that no Israeli-incorporated operating-company acquisition was identified: the filings establish the acquisition and Israeli headquarters, but the cited passages do not independently establish Holisto’s legal jurisdiction of incorporation. Israeli headquarters and Israeli incorporation must therefore remain distinct findings.17, 18

Technology Ecosystem & R&D Footprint

Research facilities and engineering

Expedia Group’s 2025 annual report describes a technology-driven business operating global travel platforms, commercial distribution infrastructure and related services.1

No public evidence identified establishing an Expedia-owned Israeli research centre, engineering laboratory, accelerator programme or identifiable Israeli R&D employee population.

AI acquisition: Layla

On 26 August 2026, law firm Noerr confirmed that it advised Expedia Group on its acquisition of Layla AI GmbH, a Berlin-based travel-planning and conversational AI company founded in 2023.19

The acting acquirer was Expedia Group, Inc., the acquired entity was Layla AI GmbH, and the announced commercial purpose was to combine AI-enabled itinerary planning and personalisation with Expedia’s inventory and booking infrastructure; the announcement appeared on noerr.com.19

This disclosed acquisition identifies Germany as Layla’s corporate location and does not establish an Israeli-domiciled acquisition or technology transfer to Israeli defence institutions.19

Technology partnerships

In March 2024, Expedia Group announced additional commercial travel-distribution and technology partnerships intended to expand the reach of its platform and travel inventory.20

The announcement describes general travel-technology distribution rather than an Israeli defence, intelligence or sovereign-cloud programme.20

Patents and Israeli research institutions

No public evidence identified of Expedia holding material patent-licensing agreements or co-development contracts with Technion, Hebrew University, the Weizmann Institute or an Israeli military technology laboratory.

No public evidence identified of Expedia acquiring an Israeli offensive cyber, surveillance, intelligence-analysis or military AI company.

Ownership and controlling principals

Expedia’s April 2026 proxy identifies Barry Diller as chairman and controlling voting principal, Ariane Gorin as chief executive, and 11 board nominees: Beverly Anderson, M. Moina Banerjee, Chelsea Clinton, Barry Diller, Henrique Dubugras, Ariane Gorin, Craig Jacobson, Dara Khosrowshahi, Patricia Menendez Cambo, Alex von Furstenberg and Alexandr Wang.21

The proxy identifies The Vanguard Group as holding approximately 13.3% of the common stock and BlackRock as holding approximately 8.7%; Barry Diller held or was attributed approximately 32.6% of aggregate voting power through common and Class B share interests.21

The proxy describes Class B shares held through Diller-associated trusts and the Diller–von Furstenberg Family Foundation, demonstrating the relevant voting-control vehicles while leaving their separate Israeli technology investments unestablished.21

Expedia’s May 2026 corporate anniversary announcement identifies Rich Barton among the company’s founding leaders, alongside Barry Diller, former CEO Dara Khosrowshahi and current CEO Ariane Gorin.10

Named principal search record

Barry Diller - chairman and voting-control principal; searched for Israeli cybersecurity, defence, intelligence and surveillance investments; no qualifying direct relationship established.

Rich Barton - founder; searched for Israeli cyber, defence and intelligence startup investments; no qualifying direct relationship established.

Ariane Gorin - CEO; searched for Israeli state technology, cybersecurity and military-commercial relationships; no qualifying direct relationship established.

Beverly Anderson - director; searched for Israeli defence and surveillance technology directorships; no qualifying relationship established.

M. Moina Banerjee - director; searched for Israeli military technology and venture investment; no qualifying relationship established.

Chelsea Clinton - director; searched for Israeli surveillance, defence and related institutional roles; no qualifying relationship established.

Henrique Dubugras - director; searched for Israeli cybersecurity and military-related investment; no qualifying relationship established.

Craig Jacobson - director; searched for Israeli defence technology and state-contract relationships; no qualifying relationship established.

Dara Khosrowshahi - director and former CEO; searched for Israeli cybersecurity, military technology and investments; no qualifying relationship established.

Patricia Menendez Cambo - director; searched for Israeli defence, cyber and investment relationships; no qualifying relationship established.

Alex von Furstenberg - director and Class B shareholder; searched for Israeli military technology and investment vehicles; no qualifying relationship established.

Alexandr Wang - director; searched for Israeli AI, defence, intelligence and technology investments; no Expedia-attributable qualifying act established.

The Vanguard Group - shareholder exceeding 10% of common stock; searched for Israeli defence and cybersecurity portfolio relationships attributable to Expedia; no qualifying Expedia-directed act established.

BlackRock, Inc. - substantial shareholder; searched for Israeli defence and cybersecurity relationships attributable to Expedia; no qualifying Expedia-directed act established.

Diller–von Furstenberg trusts and foundation - Class B holding vehicles; searched for Israeli defence and surveillance technology investment; no qualifying investment established.

Named integrated-entity search record

Expedia Group, Inc. - listed parent; searched for Israeli technology procurement, military contracts, settlements and data infrastructure; settlement-facing digital travel distribution documented.15

Expedia, Inc. - website operating subsidiary; searched for Israeli procurement and military/state technology; Expedia platform operations documented, with no separate qualifying Israeli military-technology contract identified.3

Hotels.com L.P. - subsidiary; searched for Israeli software and settlement distribution; settlement accommodation listing activity documented.14

HomeAway.com, Inc. - subsidiary; searched for Israeli technology, settlement inventory and defence provision; no separate qualifying relationship identified.

Vrbo - group platform; searched for Israeli technology intermediaries and settlement accommodation; documented Guesty connectivity and settlement listings observed in 2025.6

Travelscape, LLC - subsidiary; searched for Israeli government technology and travel-data services; no qualifying relationship identified.

Interactive Affiliate Network, LLC - subsidiary; searched for Israeli state and software relationships; no qualifying relationship identified.

EG Corporate Travel Holdings LLC - subsidiary; searched for Israeli defence and government technology agreements; no qualifying relationship identified.

Expedia.com Limited - UK subsidiary; searched for Israeli software and procurement; no qualifying relationship identified.

Expedia Lodging Partner Services Sàrl - Swiss subsidiary; searched for Israeli technology partnerships and settlement-facing contracts; no separately attributable contract identified.

Expedia Treasury Services Limited - subsidiary; searched for Israeli technology investment; no qualifying relationship identified.

Expedia Treasury US, LLC - subsidiary; searched for Israeli technology investment; no qualifying relationship identified.

Cruise, LLC - subsidiary; searched for Israeli technology and state procurement; no qualifying relationship identified.

Civil Society Scrutiny & Regulatory History

Amnesty International investigation

On 30 January 2019 [pre-2020], Amnesty International published Destination: Occupation, identifying Expedia among online travel platforms offering accommodation in Israeli settlements in occupied Palestinian territory.22

Its detailed Expedia chapter identified nine accommodation providers listed through Expedia.com and Hotels.com in the occupied West Bank and East Jerusalem, including hotels, apartments and a luxury campsite.14

The acting platform operators were Expedia Group’s Expedia.com and Hotels.com services, the direct commercial beneficiaries were participating accommodation providers, and the public channels were the two booking websites; the published investigation documented the listings in 2019 but did not establish individual platform-contract termination dates.14

Amnesty reported that Expedia maintained staff involved in accommodation-partner relationships while operating its global booking platforms; the report did not identify a local Expedia office in Israel or occupied Palestinian territory at the time.14

AFSC Investigate

AFSC Investigate maintains a company profile for Expedia Group describing the operation of Expedia.com and Hotels.com and their settlement-related accommodation listings.23

The profile is a civil-society research publication on investigate.afsc.org and identifies settlement tourism as the relevant business activity; it does not document a named Israeli cybersecurity or military cloud contract.23

Independent observations after July 2024

Reporting published in July 2025 by The Journal Investigates identified accommodation listings associated with settlements available through Expedia, Hotels.com and Vrbo.15

The report describes listings in the West Bank, occupied East Jerusalem and the Golan Heights and observed that some location information used by the platforms did not explicitly identify the settlement status of properties.15

Its July 2025 observations occurred after the International Court of Justice’s advisory opinion of 19 July 2024 and the ICC arrest warrants issued in November 2024, providing evidence of digital accommodation-distribution activity during the subsequent period.15

The reporting stated that Expedia Group had been contacted for comment but had not responded before publication; it did not establish whether Expedia later altered or removed the identified listings.15

Campaigns and company responses

Amnesty International publicly called on Expedia and other online travel companies to cease offering settlement-related accommodation services and urged government intervention in January 2019.22

AFSC continues to identify Expedia Group in its settlement-related corporate research database, providing a further documented civil-society scrutiny channel.23

No public evidence identified of a technology-specific boycott campaign directed at Expedia for supplying Israeli military cloud services, spyware or surveillance infrastructure.

Regulatory actions

On 13 June 2019 [pre-2020], the US Treasury’s Office of Foreign Assets Control announced a $325,406 settlement with Expedia Group relating to Cuba-linked travel services provided between 2011 and 2014.24

The regulator identified the acting company as Expedia Group, Inc., acting for itself and associated entities, with the conduct involving travel-service transactions rather than Israeli defence procurement or technology transfers.24

No public evidence identified of an Israeli military technology export-control prosecution, Israeli security-sector sanctions violation or regulatory action specifically concerning Expedia’s provision of surveillance technology to Israeli state bodies.

Named acts and temporal status

Act 1 - Expedia, Inc. and Hotels.com booking platforms; beneficiary: settlement accommodation providers and booking customers; channels: Expedia.com and Hotels.com, assessed through Amnesty International’s amnesty.org investigation; earliest documented observation: January 2019 [pre-2020]; latest separately corroborated observation: July 2025; status on 26 October 2026: not independently verified for each individual property; public audience: international website visitors; individual listing durations and contractual payments unavailable.14

Act 2 - Expedia Group’s Vrbo platform; beneficiary: accommodation providers and travellers; channel: Vrbo digital listing platform, independently observed through thejournal.ie; dated observation: July 2025; status on 26 October 2026: individual listings unverified; audience: public accommodation-search users; property-level booking volume and commission data unavailable.15

Act 3 - Guesty channel integration; acting technology provider: Guesty; commercial counterparties: participating Expedia/Vrbo property managers; channel: technical integration described on help.guesty.com; earliest contractual date: not established; latest observation: October 2026 documentation review; status: publicly documented integration, with individual customer contracts unknown; audience: accommodation managers and technical administrators.6

Act 4 - AWS cloud migration; acting supplier: Amazon Web Services, Inc.; beneficiary: Expedia, Inc.; channel: infrastructure migration announced on press.aboutamazon.com; dated observation: 29 November 2017 [pre-2020]; status of specific workloads in October 2026: unknown; publication audience: general corporate and technology stakeholders.8

Act 5 - Microsoft Bing distribution; acting parties: Expedia Group, Inc. and Microsoft Corporation; beneficiaries: eligible travel customers; channel: Bing booking integration, announced on ir.expediagroup.com; dated observation: 29 October 2024; subsequent termination: not identified; announcement audience: public travel customers and commercial partners.9

Act 6 - OpenAI Operator and Microsoft Copilot Actions; acting entity: Expedia Group; counterparties: OpenAI and Microsoft; channels: AI-assisted travel discovery and booking integrations announced on ir.expediagroup.com; dated observation: 14 May 2025; current availability of individual integrations: unverified; announcement audience: travellers and platform partners.16

Act 7 - Intelligent Experience Platform; acting entity: Expedia Group B2B; beneficiaries: selected commercial integration partners; channel: AI-powered travel distribution announced on ir.expediagroup.com; dated observation: 20 May 2026; status: announced as in development with selected-partner rollout planned; full implementation status and participating partners unavailable.13

Act 8 - CLEAR travel partnership; acting parties: Expedia Group and CLEAR; beneficiaries: eligible travellers and One Key members; channel: airport-related identity and travel experience, announced on ir.expediagroup.com; dated observation: 19 May 2026; current rollout and termination status: unverified; public audience: Expedia travellers and partner organisations.10

Act 9 - Layla AI acquisition; acting acquirer: Expedia Group; acquired entity: Layla AI GmbH; channel: corporate transaction described by legal adviser Noerr on noerr.com; dated confirmation: 26 August 2026; transaction reported as completed; acquired technology concerns conversational trip planning and booking, with no verified Israeli military or intelligence beneficiary.19

The dated primary source for Act 1’s July 2025 observation is Stephen McDermott’s original investigation published by The Journal Investigates on 8 July 2025, entitled “Who are the 8 companies that Ireland invests in that have links to illegal Israeli settlements?” The publisher’s contemporaneous archive independently confirms the publication date. The investigation reports that its journalists directly searched Expedia for accommodation during July and August and identified dozens of listings in settlements in the West Bank, parts of occupied East Jerusalem and the Golan Heights. It separately reports finding comparable listings through Hotels.com and Vrbo, including a property in Efrat. The investigation states that the individual listings did not identify their settlement status, although Expedia’s location-search interface sometimes used the designation “Israeli Settlement, Palestinian Territories.” This confirms the existing audit’s July 2025 observation and identifies its proper supporting source: existing End Note 7, rather than End Note 5, which documents Amnesty International’s January 2019 investigation. The 8 July 2025 publication establishes that the findings were publicly documented by that date; it does not specify the exact day on which each individual accommodation search was performed or establish continued availability in October 2026.15, 25

Footnotes

  1. Expedia Group, Inc., 2025 Form 10-K, filed 2026. https://www.sec.gov/Archives/edgar/data/1324424/000132442426000008/expe-20251231.htm ↩ ↩2

  2. Expedia Group, Inc., Exhibit 21, Subsidiaries as of 31 December 2025. https://www.sec.gov/Archives/edgar/data/1324424/000132442426000008/q42025ex-21.htm ↩

  3. Expedia, Legal Information, United Kingdom website, publicly accessible PDF copy. https://forever.travel-assets.com/flex/flexmanager/mediaasset/1305366-0_2-legal_legal_information_BEX_uk.pdf ↩ ↩2

  4. Guesty, About Us, company history and Tel Aviv headquarters. https://www.guesty.com/about-us/ ↩

  5. Guesty Help Center, About Guesty. https://help.guesty.com/hc/en-gb/articles/9391073145885-About-Guesty ↩ ↩2 ↩3

  6. Guesty Help Center, Linking Expedia listings to Guesty. https://help.guesty.com/hc/en-gb/articles/9358073761693-Linking-Expedia-listings-to-Guesty ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  7. Expedia Group, Certified Technology Partners Programme. https://partner.expediagroup.com/en-gb/solutions/build-your-travel-experience/rapid-api/certified-technology-partners-program ↩ ↩2 ↩3

  8. Amazon Web Services, Expedia Goes All-In on AWS, 29 November 2017. https://press.aboutamazon.com/2017/11/expedia-goes-all-in-on-aws ↩ ↩2 ↩3 ↩4 ↩5

  9. Expedia Group, Expedia Group and Microsoft Bing Launch New Strategic Partnership, 29 October 2024. https://ir.expediagroup.com/news-and-events/news/news-details/2024/Expedia-Group-and-Microsoft-Bing-Launch-New-Strategic-Partnership-Offering-Travelers-Additional-Loyalty-Perks/default.aspx ↩ ↩2 ↩3

  10. Expedia Group, Expedia Group Unveils New AI Experiences, Expands Travel Ecosystem and Launches Philanthropy Program at Explore 2026, 19 May 2026. https://ir.expediagroup.com/news-and-events/news/news-details/2026/Expedia-Group-Unveils-New-AI-Experiences-Expands-Travel-Ecosystem-and-Launches-Philanthropy-Program-at-Explore-2026/default.aspx ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  11. Expedia Group, B2B Privacy Statement, United Kingdom, updated 7 July 2026. https://legal.expediagroup.com/node/599 ↩ ↩2 ↩3 ↩4 ↩5

  12. Expedia Group, Consumer Privacy Statement, international processing and data transfers. https://legal.expediagroup.com/privacy_statement ↩ ↩2

  13. Expedia Group, Expedia Group B2B Introduces AI Toolkit and Platform for the Future of Travel Distribution, 20 May 2026. https://ir.expediagroup.com/news-and-events/news/news-details/2026/Expedia-Group-B2B-Introduces-AI-Toolkit-and-Platform-for-the-Future-of-Travel-Distribution/default.aspx ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  14. Amnesty International, Chapter 4: Online Tourism Companies Doing Business in the Settlements, January 2019. https://www.amnesty.org/en/latest/campaigns/2019/01/chapter-4-online-tourism-companies-doing-business-in-the-settlements/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  15. The Journal Investigates, Who are the 8 companies that Ireland invests in that have links to illegal Israeli settlements?, July 2025. https://www.thejournal.ie/investigates-state-investments-settlements-6740909-Jul2025/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  16. Expedia Group, Expedia Group Expands B2B Platform and Launches GenAI Partnerships, 14 May 2025. https://ir.expediagroup.com/news-and-events/news/news-details/2025/EXPEDIA-GROUP-EXPANDS-B2B-PLATFORM-AND-LAUNCHES-GENAI-PARTNERSHIPS-TO-ENHANCE-TRAVEL-DISCOVERY/default.aspx ↩ ↩2 ↩3 ↩4

  17. trivago N.V., Annual Report on Form 20-F for the year ended 31 December 2025, filed 2026, sections on Expedia Group ownership, business strategy, Holisto Investment and Acquisition, and related-party transactions. https://www.sec.gov/Archives/edgar/data/1683825/000168382526000006/trvg-20251231.htm ↩ ↩2 ↩3 ↩4 ↩5

  18. trivago N.V., Form 6-K, Completion of Acquisition of Holisto Limited, 31 July 2025. https://www.sec.gov/Archives/edgar/data/1683825/000168382525000033/form6-k2025closingofprojec.htm ↩ ↩2

  19. Noerr, Noerr advises Expedia Group on acquisition of Layla AI, 26 August 2026. https://www.noerr.com/en/press/20260826-expedia-layla-ai ↩ ↩2 ↩3 ↩4

  20. Expedia Group, Expedia Group Welcomes New Partners to its Global Travel Ecosystem, 13 March 2024. https://ir.expediagroup.com/news-and-events/news/news-details/2024/Expedia-Group-Welcomes-New-Partners-to-its-Global-Travel-Ecosystem/default.aspx ↩ ↩2

  21. Expedia Group, Inc., 2026 Definitive Proxy Statement, 29 April 2026. https://www.sec.gov/Archives/edgar/data/1324424/000132442426000022/expe-20260429.htm ↩ ↩2 ↩3

  22. Amnesty International, Destination: Occupation, 30 January 2019. https://www.amnesty.org/en/documents/mde15/9490/2019/en/ ↩ ↩2

  23. American Friends Service Committee, AFSC Investigate, Expedia Group Inc., company investigation. https://investigate.afsc.org/company/expedia-group ↩ ↩2 ↩3

  24. US Treasury, Office of Foreign Assets Control, Settlement Agreements between OFAC and Expedia Group, Inc. and others, 13 June 2019. https://ofac.treasury.gov/recent-actions/20190613 ↩ ↩2

  25. The 42, Stephen McDermott author archive, page 4, independently listing the investigation and its publication date of 8 July 2025. https://www.the42.ie/author/stephen-mcdermott/6091/page/4/ ↩