28Similarly, while the provisions under Section 4 of Chapter II of Regulation No 1215/2012, on ‘Jurisdiction over consumer contracts’, also establish a rule of special jurisdiction for consumers, and although an airline passenger may be considered to be a consumer, it should be noted that Article 17(3) of that regulation states that Section 4 ‘shall not apply to a contract of transport other than a contract which, for an inclusive price, provides for a combination of travel and accommodation’.
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