Wi-Fi available on one in three U.S. planes

Wi-Fi service is offered on more than one-third of the nation's passenger planes, so it's no longer rare to see travelers connecting to the Internet in midflight.

Business travelers might find wireless service on long flights to be so valuable-for, say, answering e-mails or connecting to a company VPN-that they're willing to pay Gogo's prices, Gold noted. "Business types with a pressing need will use it, but then they can expense it," he said. For casual users, on the other hand, "I think the Wi-Fi price is still a bit too high," he said.

Wi-Fi has grown more common on U.S. flights even though the airlines have restricted passengers from using voice over Wi-Fi (or video chat) systems. Some airlines have said they don't believe passengers want to hear their fellow travelers engage in phone conversations during flights, although airlines in some other countries allow video chat.

Aircell has "multiple protocols and practices in place" to prevent the use of voice-over-IP systems, said a company spokeswoman. However, she acknowledged that it's "extremely difficult to stop every instance of VoIP." A recent New York Times article described a Skype call that took place on a Virgin America flight, and this reporter conducted a short video chat on a Virgin flight last December.