Airbnb and Generali Hid Illegal Fees Inside Every Travel Insurance Checkout
The Non-Financial Ledger
Gina Bentley-Nehrhood lives in Graham, Washington. At some point in September 2023, she sat down to book a stay on Airbnb. She went through the checkout process the same way millions of people do, reading what was on the screen, trusting that the price quoted for travel insurance was the price of travel insurance. She clicked the box. She paid. She thought she was protected.
She was not told she was also paying for something else.
Rami Amaro lives in Friday Harbor, Washington. Between 2017 and 2023, she made nine separate Airbnb bookings. At least once, in 2023, she added travel insurance during checkout. She did the same thing Bentley-Nehrhood did. She read the screen. She trusted the price. She clicked the box.
Neither woman was told what portion of their payment was the actual regulated insurance premium. Neither was told that a separate fee had been folded into that single number. Neither was given a choice to decline that fee. Neither was given the option to pay only for the insurance they came to buy.
The complaint is careful about this. It does not allege that these women are unusual or that they missed something obvious. The entire legal argument rests on the opposite claim: that Airbnb and Generali built a checkout process specifically so that a careful, reasonable consumer reading everything on the screen still could not find the fee. The “Important Disclosures” hyperlink, the only place any hint of the fee appeared, was not required to complete a purchase. A consumer had no reason to think a separate fee existed, and therefore no reason to go looking for one.
And even if they did look. Even if they clicked the non-required link and found the “Important Disclosures” page. The actual dollar amount of the fee was still not written there. To get that number, a consumer had to contact Defendants directly by email and wait for a response.
Think about what that means in practice. You book a vacation. You add insurance. You pay. The confirmation arrives. You feel prepared. Somewhere inside that single line item price, a fee you never agreed to was collected. A fee that Washington regulators never approved. A fee that exists, according to the lawsuit, as a mechanism to extract money above the legal limit while keeping regulators from ever seeing what was actually being charged.
The system was not broken. The complaint argues it worked exactly as designed.
The harm to each individual consumer may feel small in isolation, the difference between an approved premium and a bundled fee on one travel insurance purchase. But across thousands of Washington consumers making bookings on one of the most widely used platforms on earth, the class action argues this scheme generated millions of dollars in fees that were never legally permitted, never clearly disclosed, and never genuinely consented to. The two women who put their names on this lawsuit did so knowing most of the people they are representing have no idea this happened to them.
Legal Receipts
The following passages are drawn directly from the class action complaint filed October 30, 2024, in Case 2:24-cv-01787. They are the complaint’s own words documenting how the scheme operated and what consumers were denied.
“Although their travel insurance offers are presented for a price that appears to be the insurance premium, Defendants secretly and unfairly charge unsuspecting consumers additional fees, on top of the calculated premium, without disclosing the nature of those fees and without giving consumers an option to pay only the approved premium for the travel insurance according to the filed and approved rate for that insurance.”
- This establishes the core deception: the price shown on the checkout screen was presented as the insurance premium, when in fact it was the premium plus an undisclosed additional fee. The consumer had no way to know the difference from what was displayed.
- The phrase “filed and approved rate” is legally significant. Washington requires insurers to submit their premium rates to regulators for approval before charging consumers. The complaint alleges Defendants charged consumers a total amount that was never submitted for regulatory approval, bypassing the entire oversight process.
- Consumers were given no option to purchase only the approved, regulated insurance. The fee was mandatory, non-negotiable, and structurally invisible inside the single quoted price.
“Moreover, the ‘Important Disclosures’ still does not disclose the amount of the fee and requires consumers to send an email to ask Defendants to disclose the fee. Defendants know that, and have designed the checkout process such that, consumers are highly unlikely to discover the existence of the amount of the assistance fee or make an inquiry about it.”
- This is the complaint’s most direct statement of intent. It argues the omission of the fee amount from the “Important Disclosures” page was not an oversight. Defendants knew consumers would not go looking for a fee they had no reason to suspect existed, and the checkout was built on that knowledge.
- Requiring consumers to send an email to learn what they were charged is a deliberate friction barrier. It ensures that only the most persistent consumers would ever find the fee amount, and by that point the purchase was already complete.
- This supports the complaint’s Consumer Protection Act claim: a practice is deceptive when it has the capacity to deceive a substantial portion of consumers. A fee hidden behind a non-required link that still does not disclose the dollar amount meets that threshold.
“Regardless of how Defendants’ ‘assistance’ fees are ultimately characterized — whether as an artifice to collect an unlawful agent’s fee or unauthorized premium or as genuinely for non-insurance services (that no one has chosen and that few people would pay for if given the choice) — the result is the same: Defendants collect more from consumers than they should.”
- The complaint removes Defendants’ primary escape route. Even if a court accepted that the “assistance services” were genuinely separate from the insurance, the bundling of those services without disclosure and without the option to decline still violates Washington law. The legal violation does not depend on how the fee is categorized.
- The parenthetical phrase “that no one has chosen and that few people would pay for if given the choice” is pivotal. It anticipates a defense that the fee was for legitimate services with real value and directly counters it: the market did not demand these services, consumers did not seek them out, and their pricing was never tested against consumer willingness to pay.
- This framing strengthens both causes of action simultaneously, the Consumer Protection Act claim and the breach of the duty of good faith claim, because both rest on the same underlying fact: more money was taken than the law permitted.
“This substantial cumulative harm to consumers is not outweighed by any countervailing benefits. There is no benefit in forcing consumers to pay fees that they do not want to pay… Defendants already have automated processes to immediately calculate an insurance premium and assistance fee in connection with each offer and sale; there is no utility in Defendants’ refusal to simply state those prices separately and to provide consumers the option to decline the assistance fee.”
- The complaint identifies that Defendants already calculate the premium and fee as separate numbers in their own automated systems. They simply chose not to display them separately to consumers. This means disclosure was technically trivial and was specifically withheld.
- The phrase “millions of dollars in fees, each year” appears in this paragraph’s surrounding context in the complaint, directly quantifying the class-wide harm. Defendants were collecting this scale of unlawful revenue from a population of consumers who, the complaint argues, would have declined to pay the fee if offered the choice.
- The argument that there is “no utility” in refusing to separate the prices is a direct challenge to any efficiency or design justification Defendants might offer. The system was built to obscure, not to streamline.
Societal Impact Mapping
Public Health: The Regulatory Ecosystem
Insurance rate regulation exists to protect consumers the same way food safety regulation protects the public. When that regulation is bypassed at scale, the damage is structural.
- Washington’s insurance regulatory framework requires that all premium rates be submitted to and approved by the Insurance Commissioner before they are charged to consumers. The complaint alleges Defendants charged consumers a bundled total that was never approved, meaning the entire oversight mechanism was circumvented for every single transaction in the class period.
- The complaint states the class period covers more than four years of ongoing conduct. Every travel insurance purchase on Airbnb.com in Washington during those four-plus years is alleged to have included this undisclosed, unapproved fee. The volume of affected transactions is described as numbering in the thousands at minimum.
- By hiding fees inside a single presented price, Defendants ensured that even consumers who tried to shop carefully for insurance could not compare the actual regulated premium against what they were being charged. Informed consumer choice, the foundation of market regulation, was made structurally impossible at the checkout level.
- The complaint notes that Generali’s insurance offer was the only insurance option presented to consumers during the Airbnb checkout process. There was no competing insurer visible, no alternative to evaluate, and no ability for consumers to opt out of the assistance fee while still purchasing the only available insurance product. This is a captive market by design.
Economic Inequality
Hidden fees in consumer financial products do not affect all demographics equally. The travelers most harmed are those with the least capacity to absorb unexpected charges and the least access to legal recourse.
- The class encompasses all Washington residents who purchased travel insurance from Generali through the relevant booking platforms during the class period, estimated to number in the thousands. The complaint seeks compensatory, statutory, and treble damages on behalf of this entire class, meaning the total financial remedy sought could be three times the aggregate overcharge.
- Consumers who purchased travel insurance were, by definition, attempting to protect themselves from financial risk. The assistance fee extracted money from consumers who were specifically trying to be financially responsible, turning a consumer protection product into a vehicle for the very kind of hidden financial extraction those consumers were trying to guard against.
- The complaint argues Defendants were “unjustly enriched” by the scheme, a legal standard requiring disgorgement of profits that were obtained unfairly. If the complaint’s characterization holds, every dollar collected in assistance fees above the approved premium represents a transfer of wealth from individual consumers to a New York-based corporation and an Italy-headquartered global insurance giant, with zero regulatory oversight of that transfer.
- The complaint specifically notes that Defendants registered with the Washington Office of the Insurance Commissioner to sell travel insurance in Washington. Registration implies compliance with state law. The lawsuit alleges registration was a cover for a fee structure that violated the very laws governing registered insurers in that state.
- The Washington Consumer Protection Act provision invoked here allows for treble damages on proven violations. This multiplier exists precisely to deter corporations from calculating that the profit from a hidden fee scheme exceeds the cost of any eventual legal settlement. The class action mechanism forces the math to change.
The Checkout Anatomy: What Was Shown vs. What Was Hidden
The complaint includes screenshots of the Airbnb checkout flow. The chart below maps what information was disclosed versus what was withheld at each stage of the purchase process documented in the lawsuit.
What Now?
The lawsuit names corporate roles and entities who are accountable for this scheme and identifies the regulatory bodies with jurisdiction to act. Here is what to watch and what to do.
The Defendants
- Airbnb Insurance Agency LLC, a New York corporation, principal place of business at 222 Broadway, New York, NY 10038. Named as the agent who sold and collected on behalf of Generali and who designed the checkout flow at issue.
- Generali Assicurazioni Generali S.P.A. (U.S. Branch), domiciled in New York, principal place of business at 250 Greenwich Street, 7 World Trade Center, New York, NY 10007. Named as the insurer who created, maintained, marketed, and collected on the insurance products at issue.
- Plaintiffs are represented by Bursor & Fisher, P.A. (attorneys Brittany S. Scott and Joshua R. Wilner) and Carson Noel PLLC (attorney Wright A. Noel, WSBA #25264).
Regulatory Watchlist
- Washington Office of the Insurance Commissioner (OIC): The primary regulatory body for insurance rate approval in Washington state. Both Defendants are registered with the OIC. File a consumer complaint at insurance.wa.gov if you purchased travel insurance through Airbnb in Washington during or after 2020.
- Washington State Attorney General’s Office (Consumer Protection Division): The AG enforces the Washington Consumer Protection Act, the same statute cited in this lawsuit. Consumer complaints can trigger independent investigations separate from the civil class action.
- Federal Trade Commission (FTC): The FTC maintains jurisdiction over deceptive practices in interstate commerce. An online booking platform operating across all 50 states falls squarely within FTC reach. Consumer complaints build the record for federal action.
- Consumer Financial Protection Bureau (CFPB): The CFPB has authority over consumer financial products, including insurance-adjacent products sold through digital platforms. Submit a complaint at consumerfinance.gov/complaint if you believe you were charged undisclosed fees.
What You Can Do Right Now
- Check your Airbnb purchase history. If you are a Washington state resident and you added travel insurance to any Airbnb booking from approximately 2020 onward, you may be a class member. Review your email confirmations and payment records for any line item labeled “travel insurance” on airbnb.com.
- Contact class counsel directly. Bursor & Fisher, P.A. can be reached at bscott@bursor.com or jwilner@bursor.com, (925) 300-4455. Carson Noel PLLC can be reached at wright@carsonnoel.com, (425) 837-4717. You do not need to pay anything to inquire about your potential class membership.
- File a complaint with the Washington OIC. Even if you are not a Washington resident, if you purchased travel insurance through a booking platform and believe you were charged fees that were not disclosed or approved, your state’s insurance commissioner has equivalent authority and wants to hear from you.
- Share this investigation with every traveler you know. The class is estimated to include thousands of people who have no idea this happened to them. Most will never see a legal notice. Word of mouth between travelers is how class members find out they have claims. Share the case number: 2:24-cv-01787, Western District of Washington.
- Before your next booking, read every line of the insurance offer carefully, click every disclosure link, and if you cannot identify exactly what portion of the price is the regulated premium versus any additional fee, consider declining the add-on insurance and purchasing a standalone travel insurance policy directly from a licensed insurer of your choosing, where rate transparency is clearer and competition exists.
The source document for this investigation is attached below.
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