Indeed. DOT fines tend to be small in this area. On the other hand, it is notable that DOT considered and rejected each of AA's defenses. That could be useful

Indeed. DOT fines tend to be small in this area. On the other hand, it is notable that DOT considered and rejected each of AA's defenses. That could be useful as precedent. Some passengers may also have meritorious claims they'd like to bring against AA on an individual basis.