TripAdvisor

Key Findings

• Settlements (Digital/Economic): Tripadvisor.com, Viator and FlipKey list or book settlement accommodation, attractions and tours. Who Profits counts 8 West Bank, 3 East Jerusalem and 38 Golan listings across 13 settlements, plus City of David, Susya and Gush Etzion attractions.¹ Amnesty (2019) found 70+ listings in 27 settlements.²
• Economic: Amnesty describes Tripadvisor as earning advertising revenue and 12–15% booking commissions on accommodation.³ No Israeli subsidiary, investment or Israel revenue disclosure is documented.^{1, 4}
• Political: Tripadvisor’s recorded position is that a listing is not an endorsement and that it does not remove active listings.^{5, 6} It stayed on the UN settlement-business database in September 2025.^{7, 8} A 2024 shareholder proposal citing settlements was withdrawn before a vote.^{9, 10, 11}
• Not found: No defence contracts, military supply, Israeli-origin technology vendors, Israeli subsidiaries or R&D presence are documented.^{12, 13, 4}

Target Profile

Key Facts:

• About 2,590 employees; leased HQ of about 280,000 sq ft in Needham; no Israel office or owned real estate.⁴
• Subsidiaries listed in Exhibit 21.1 (US, UK, Europe, Australia, India, Japan, Singapore, China and elsewhere) include none incorporated in Israel.¹³
• The merger buying out Liberty TripAdvisor had an aggregate transaction value of about $430 million.¹⁴

Executive Summary

Tripadvisor is a US-listed travel platform, not a manufacturer, retailer or technology vendor to Israeli state bodies. Its documented Israel/Palestine nexus is that its flagship site and its Viator and FlipKey brands list and book accommodation, attractions and tours in Israeli settlements in the occupied West Bank, East Jerusalem and Golan Heights.^{12, 1} Examples include Elad-run City of David tours and the Caliber 3 shooting and “counter-terrorism boot camp” activity.^{1, 3} The sources are Who Profits, Amnesty (2019), AFSC and press reports.

The company’s recorded response, in February 2019, July 2019 and June 2020, is that listings are not endorsements, that it aims at an “apolitical, accurate and useful picture”, and that it does not remove listings of businesses that remain open.^{5, 6, 18} Amnesty said no policies had changed by June 2020.¹⁸ The company stayed on the UN settlement-business database in September 2025, after the 19 July 2024 ICJ advisory opinion.^{7, 8} The audits cannot confirm whether the listings themselves continued after 2019. Dated listing observations stop at 2019 (Amnesty, BHRRC), and the Who Profits profile (valid to 02/07/2026) has no collection date.^{1, 19}

The audits do not support any military, defence or surveillance link. They find no defence contracts, no Israeli-origin technology vendors, no Israeli subsidiaries or R&D, no Israel revenue disclosure and no Israeli controlling owner.^{12, 4, 13} Its cloud use (AWS and Google Workspace) is documented, but no participation in Project Nimbus is.^{4, 20, 21} Press reports that Tripadvisor remained on the database are sourced to secondary reports, because the primary UN documents were not read. The category under which it was listed in 2020 is unconfirmed.²²

Settlement operations score in two domains (Economic and Political). The vetted result is Military 0.00, Digital 6.41, Economic 6.41 and Political 6.90, giving BRS 646, Tier B (Severe Complicity).

Timeline of Relevant Events

Corporate Overview

Tripadvisor LLC was founded in February 2000 by Stephen Kaufer, Langley Steinert, Nick Shanny and Thomas Palka. IAC acquired it in 2004, and Expedia spun it off as a public company in December 2011.²² No public evidence identified of any Israeli founding, incorporation, headquarters, tax residency or Israeli beneficial ownership.^{22, 1}

Subsidiaries include Viator, Inc., FlipKey, LLC, Bokun, Owl Analytics, SinglePlatform and technology entities in Romania, Croatia, Iceland and India. None is in Israel.¹³ Liberty TripAdvisor Holdings was the former controlling holder. The audits give differing figures for its stake: about 11% per the FY2025 10-K and 2025 proxy, versus about 19% economic and 56% voting interest as of 31 December 2024 in the Military audit’s reading of the FY2024 10-K. All agree the merger ended its control on 29 April 2025.^{4, 17, 14} The exact legal entity operating each settlement listing is not established.^{1, 3}

Domain Summaries

Military: Military

Mechanism of Involvement

No mechanically eligible frame was found; Military is 0.00. No public evidence identified of contracts with the Ministry of Defence, IDF, Prison Service or Border Police, of defence-prime supply, or of military or dual-use products.¹² The only military-adjacent item is a consumer booking listing, Caliber 3. AFSC says it is a “counter-terrorism boot camp” using TripAdvisor for bookings, and Amnesty priced a “2-hour shooting experience” at US$170.^{12, 3} This is an advertised tourist activity and not a service to a military installation.

Counter-Arguments and Evidence Limits

The Reuters bootcamp story does not name Caliber 3 or Tripadvisor, so the link rests on AFSC’s characterisation.²³ The status of the listing at the research date is unknown, because AFSC’s page was valid as of 21 August 2022.¹² The FY2023 and FY2024 10-K text reviewed contains no Israel or defence mention.

Named Entities and Evidence Map

Tripadvisor, Liberty TripAdvisor, Maffei, Kaufer, Goldberg, Starboard and Certares were searched against Elbit, Rafael, IDF and similar terms, and none was found. Reservist-pay and donation-matching policies: no public evidence identified.¹²

Digital: Digital

Mechanism of Involvement

The domain applies the settlement-nexus clause: the flagship site, Viator and FlipKey list and book settlement accommodation, attractions and tours.^{1, 3} Who Profits records 8 West Bank, 3 East Jerusalem and 38 Golan listings across 13 settlements, plus City of David, Susya and Gush Etzion attractions.¹ Amnesty (2019) found at least 70 listings in 27 settlements, with Tripadvisor acting as booking agent for the Elad-run City of David.² Amnesty also reported inconsistent location labelling, for example Shiloh listed without a settlement note.³ Who Profits (2017) found settlement properties presented as being in Israel.²⁴ The Jerusalem Post headlined in 2019 that Efrat and Ariel were placed in “Palestinian Territories”.²⁹

Counter-Arguments and Evidence Limits

No public evidence identified of Israeli-origin technology (Check Point, Wiz, SentinelOne, Palo Alto and others), surveillance or biometrics, Israeli data centres or R&D, AI supplied to Israeli state bodies, or Israeli technology acquisitions.^{4, 13, 20} Its documented stack is AWS and Google Workspace. Google and AWS won Project Nimbus, but no public evidence identified that Tripadvisor participates in it or runs workloads in Israeli regions.^{4, 20, 21, 30} The 10-K mentions the Israel-Hamas conflict only as a travel-demand risk.⁴ Dated listing captures stop at 2019, and continuation to 2026 rests on the Who Profits profile and database retention.^{1, 7}

Named Entities and Evidence Map

Viator and FlipKey carry the settlement listings.^{12, 1} Directors and executives (Maffei, Goldberg, nominees) show no Israel technology link in the proxy portions reviewed.¹⁶

Economic: Economic

Mechanism of Involvement

Indirect portfolio flow is negated: there is no Israel-investing parent, and Liberty TripAdvisor became a wholly owned subsidiary in April 2025.^{4, 14} The act is direct commission revenue (12–15% per Amnesty) from settlement enterprise booked through tripadvisor.com, viator.com and holidaylettings.co.uk.³ That enterprise includes Elad City of David tours, Caliber 3, Ariel and Ma’ale Adumim accommodation, 38 Golan listings and settlement wineries (Psagot, Drimia, La Foret Blanche, Beit El, Har Bracha). The wineries are a listing relationship and not a documented purchase.¹ Amnesty reported that Tripadvisor was the second most visited information site among foreign tourists in Israel, and that over 800,000 people consulted it in 2017.³ Amnesty’s spokesperson said listings “pump money into the settlement economy”; this is an advocacy characterisation.³¹

Counter-Arguments and Evidence Limits

No public evidence identified of Israel revenue disclosure, Israeli suppliers, importer-of-record roles, Israeli subsidiaries, investments, offices, workforce or tax status.^{1, 4} No Israeli state or capital ownership is identified.¹ The 10-K says “we do not own any real estate”.⁴ The settlement listings are a listing relationship and not a documented sale of goods. The HRW tourism report does not cover Tripadvisor.²⁵ AFSC’s divestment references are advocacy positions and not findings of fact.¹²

Named Entities and Evidence Map

• Starboard (9%, 3 July 2025; 8.13% per Who Profits): its Israeli investments, if any, are unverified.^{15, 1}
• BlackRock, Vanguard: no Israel-specific act related to Tripadvisor is identified.¹
• Kaufer: a 2015 profile reports personal ties to Israel (a 1989 honeymoon, children on Birthright). It records no Israeli office, business tie or donation, and is [pre-2020].³²

Political: Political

Mechanism of Involvement

The settlement-listing frame includes the company’s repeated position that it does not remove active listings.^{5, 6, 18} Notice is documented by the 2019–2020 Amnesty campaign and the 2024 shareholder proposal, which cited settlements. The Board recommended a vote against on the basis that the report “would not provide additional information”.⁹ The proposal was withdrawn on 30 May 2024 with no reason given.¹⁰ The UN database retention in September 2025 post-dates the ICJ opinion (19 July 2024) and the ICC warrants (November 2024), but no source says whether listings changed after those dates.⁷ Amnesty said the company’s response “completely ignores the hard facts of international law”.³¹ By contrast, in March 2022 Tripadvisor cancelled Russia and Belarus bookings and moderated war-related reviews.³³

Counter-Arguments and Evidence Limits

No public evidence identified of a corporate statement on Gaza or the October 2023 attacks, lobbying or PAC activity (disclosure records were not retrieved, so this is a gap and not a negative finding), state partnerships, Brand Israel sponsorships, donations to settlement or military bodies, or employee disputes.^{4, 17} The company says its practices match industry and search-engine standards.⁶ The proposal was withdrawn before the ICJ opinion and no vote was held.¹¹ Reuters-derived text names Tripadvisor as remaining on the 2025 list, but the Business & Human Rights Resource Centre and The National summaries, as retrieved, do not.^{8, 34} No public evidence identified that A/HRC/59/23 names Tripadvisor. There is no BDS Movement named-list entry in the pages searched.¹²

Named Entities and Evidence Map

Maffei (Chair; also on other boards) and Goldberg (CEO): searched, none found.¹⁷ Kaufer: no executive statement on the conflict; his 2019 refugee op-ed is unrelated to it.³⁵ Barry Diller and other directors: no Israel-related role.¹⁷

Complicity Index Score

Method: V6.6 (vetted).

• V_MAX: 6.90 Avg_OTHERS: 4.27
• BRS Score: 646 Tier: B (Severe Complicity)

V_MAX comes from Political, driven by the company’s stated policy of retaining active settlement listings despite documented notice. The Digital and Economic scores reflect direct commission-earning settlement listings through its own platforms, with a moderate magnitude. Military is zero because no eligible frame exists. The method is scale-free and evidence-only, and the final bands were examiner-adjudicated.

Methodology Note

• Evidence-only: every claim traces to the four domain audits, and “No public evidence identified” is used where checks found nothing.
• Scale-free scoring: Impact reflects activity type, Magnitude reflects scale, and Proximity reflects directness.
• Temporal rule: divested or exited operations are mitigated, and [pre-2020] and older-than-five-years evidence is flagged. The Liberty control relationship ended 29 April 2025.
• Entity attribution: no transitive guilt. Shareholders and executives are not scored for Tripadvisor’s acts without a documented link.
• Settlement operations dual-count under Economic and Political.
• Press-reported items (UN database retention, the 2026 update) are carried as press reports because the primary UN documents were not read.