Incidentally, I reported the matter to ORR over a year ago and I see they have finally published the outcome in March.
Seatfrog replied with nonsense and a clear attempt to mislead ORR.
The ORR accepted the misinformation and plans to take no action, and therefore Seatfrog feel emboldened to continue to engage in drip pricing.
I have plenty of evidence of wrongdoing by Seatfrog and would welcome anyone at ORR contacting me if they would like this evidence.
It's worth noting that Seatfrog erroneously calls this a 'platform fee', yet charges per upgrade, so two passengers means two fees!
There is no fee to use their platform for swaps.
Seatfrog try to blame train companies for the fees, however Seatfrog choose not to issue fees for swaps but to charge fees for upgrades, because they know that it's a value added product and that enough people will pay it to make the fee viable.
If anyone was to take this to court, the providing they had sufficient legal knowledge and also knowledge of the rail ticketing system and sufficient evidence of what Seatfrog are up to, I can certainly envisage Seatfrog losing a case.
If any solicitors are resting this and are interested in pursuing this, please do contact me.