TicketNetwork submitted formal comments this week to the U.S. Department of Justice and Federal Trade Commission in response to their request for public input on unfair practices in the live event ticket marketplace. This response details concrete steps to fix the broken live-event ticket marketplace, drawing on state investigations, academic research, and consumer-complaint data to show how a single vertically integrated gatekeeper inflates prices, restricts choice, and harvests fan data.
“Consumers are fed up with the modern ticketing system, and deserve better,” says TicketNetwork CEO Don Vaccaro. “Concentrated market power, deceptive price inflation tactics, anti-competitive technology, and consumer rights being shredded by fine print terms and conditions make ticket buying a rigged game. These common-sense standards would resore transparency, liquidity, and true price competition to the industry.”
Why Reform Matters
For consumers, there are interlocking problems that form the core of the current system’s failures:
- Deceptive Tactics to Imply Scarcity
- Vertical Integration & Exclusive Venue Contracts
- Primary Seller Participation in Resale Markets
- Transfer-restriction Schemes
- Poor BOTS Act Enforcement
- Market Manipulation via Price Caps & Price Floors
- Refund Delays
- Forced Arbitration
Solutions For Everyone
TicketNetwork’s Suggested Remedies Include:
- Holdback transparency. Require primary sellers to publish the exact share of seats reserved for presales, VIP packages, and insider holds—before any ticket goes on sale.
- Guaranteed ticket portability. Every ticket must be available in a freely transferable format (barcode, PDF, NFT) at no extra cost.
- Nationwide all-in pricing. The first price fans see must include all mandatory fees—no drip pricing, ever.
- Cap on exclusivity. Limit venue-ticketing contracts to five years and ban promoter retaliation when a venue chooses a rival service.
- Open-data interoperability. Establish an API standard so barcodes can be validated across any certified resale exchange.
- Automatic refunds. Full cash refunds (ticket + fees) within seven business days for cancelled events; 60-day option for long postponements.
- Bot-incident reporting. Mandate 48-hour disclosure of large bot attacks and fund enforcement with civil penalties.
- Ban on resale price floors. Primary sellers and promoters cannot set minimum resale prices.
- Pre-empt harmful price caps. Federal rules should override state or promoter caps that push fans to black-market sellers and raise fraud.
- Fair dispute resolution. Provide local small-claims or in-state arbitration and a 30-day opt-out; presumptively invalidate class-action waivers buried in click-wrap.
Read the Full Filing
TicketNetwork’s full filing is available in PDF form: