ConSeaAir arranges charter flights on behalf of its clients using the services of Federal Aviation Administration certificated air carriers operating under Part 135 and Part 121 of the Federal Aviation Regulations and applicable U.S. DOT regulations. These carriers, and not ConSeaAir, exercise full operational control of all charter flights arranged by ConSeaAir on behalf of its clients. When booking charter flights, ConSeaAir acts in the capacity of agent for the client and not as principal. ConSeaAir does not operate or maintain any aircraft that it may arrange to charter on behalf of a client. ConSeaAir does not act as an “indirect air carrier” when it arranges charter flights on behalf of its clients.