Air Canada is seeking the dismissal of the U.S. Department of Transportation’s $25.5-million U.S. fine over the airline’s alleged failure to provide prompt refunds after cancelling flights amid the COVID-19 pandemic.

In a 46-page motion filed Wednesday, the Montreal-based airline presented a series of arguments against the fine, including that the facts relied upon by the agency are insufficient to legally establish violations.

Air Canada says its refund policy complied with the U.S. transportation department’s refund regulations and its conditions of carriage. It says the D.O.T. relied on non-legally binding directives in an industry letter and has not conducted a “thorough well-reasoned analysis.”

It also contends that the enforcement complaint fails to demonstrate that the airline’s refund policy caused or was likely to cause substantial harm that could not be reasonably avoided.

A Department of Transportation administrative law judge will rule on the “notice of enforcement proceeding” issued by the department two weeks ago, where its aviation consumer protection agency said Air Canada “unlawfully failed to provide timely refunds” for flights between the United States and Canada that were cancelled or significantly changed.

The agency said it received more than 6,000 refund complaints since March 1, 2020, and has notified Air Canada multiple times over the past year of its view that the airline’s stance “lacks merit.”