In Nader v. Allegheny Airlines (1976) 426 U.S. 290, the plaintiff challenged the defendant's fraudulent misrepresentation of its practice of overbooking flights, which resulted in "bumping" passengers from their reserved seats. (Id. at pp. 295, 296.) The Federal Aviation Act authorized the Civil Aeronautics Board to determine whether an air carrier had engaged in " 'unfair or deceptive practices,' " but a saving clause expressly preserved other statutory and common law remedies. ( Id. at pp. 296, fn. 7, 298.) The high court concluded that the statutory scheme did not irreconcilably conflict with or preempt a state common law fraud action. (Id. at pp. 299-300 96 S. Ct. at pp. 1984-1985.) The court stated that the plaintiff's claim did not directly challenge the agency's ratemaking power and that any impact on rates resulting from the imposition of tort liability "would be merely incidental." (Nader v. Allegheny Airlines, supra, 426 U.S. at pp. 299-300.) It noted that the plaintiff did not challenge the reasonableness of an agency requirement or practice included within the filed tariff, since there was no agency or tariff requirement that air carriers overbook flights or that they fail to disclose the practice, and therefore concluded that the filed rate doctrine did not apply. (Id. at pp. 299-300, 304.)