***Link*** :: [BlackBird Air Constitutes Holding Out](https://download.aopa.org/advocacy/2019/1219-blackbird%20letter.pdf) ***Description*** :: `= this.link` ***Author*** :: [[FAA Office of the Chief Counsel]] ***Key Quotes***: * pilots participating in BlackBird's platform and using its app are [[holding out]] and thus are engaged in [[common carriage]] * Because these operations are subject to [[part 119]] certification, a pilot who holds an [[airline transport pilot]] or [[commercial pilot]] certificate must obtain and hold a certificate issued under [[Part 135]] or the pilot must be employed by a company operating the flight that is certificated under part 119. #source #legal-interpretation