EVENT TICKET 

SALES 

Market Characteristics 

and Consumer 

Protection Issues

Report to Congressional Requesters

April 2018

GAO-18-347

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-347, a report to 

congressional requesters

April 2018

EVENT TICKET SALES

Market Characteristics and Consumer Protection

Issues

What GAO Found

Ticket pricing, resale activity, and fees for events vary. Tickets to popular events 

sold on the primary market sometimes are priced below the market price, partly 

because performers want to make tickets affordable and maintain fans’ goodwill,

according to industry representatives. Tickets are often resold on the secondary 

market at prices above face value. In a nongeneralizable sample of events GAO

reviewed, primary and secondary market ticketing companies charged total fees 

averaging 27 percent and 31 percent, respectively, of the ticket’s price.

Consumer protection issues include difficulty buying tickets at face value and the 

fees and marketing practices of some market participants. 

• Professional resellers, or brokers, have a competitive advantage over 

consumers in buying tickets as soon as they are released. Brokers can use 

numerous staff and software (“bots”) to rapidly buy many tickets. As a result, 

many consumers can buy tickets only on the resale market at a substantial 

markup. 

• Some ticket websites GAO reviewed did not clearly display fees or disclosed 

them only after users entered payment information.

• “White-label” resale sites, which often appear as paid results of Internet 

searches for venues and events, often charged higher fees than other ticket 

websites—sometimes in excess of 40 percent of the ticket price—and used 

marketing that might mislead users to think they were buying tickets from the 

venue. 

Selected approaches GAO reviewed, such as ticket resale restrictions and 

disclosure requirements, would have varying effects on consumers and 

businesses.

• Nontransferable tickets. At least three states restrict nontransferable 

tickets—that is, tickets whose terms do not allow resale. Nontransferable 

tickets allow more consumers to access tickets at a face-value price. 

However, they also limit consumers’ ability to sell tickets they cannot use, 

can create inconvenience by requiring identification at the venue, and 

according to economists, prevent efficient allocation of tickets.

• Price caps. Several states cap the price at which tickets can be resold. But 

according to some state government studies, the caps generally are not 

effective because they are difficult to enforce. 

• Disclosure requirements. Stakeholders and government research GAO 

consulted generally supported measures to ensure clearer and earlier 

disclosure of ticket fees, although views varied on the best approach (for 

example, to include fees in an “all-in” price or disclose them separately).

Some market-based approaches are being used or explored that seek to 

address concerns about secondary market activity. These approaches include 

technological tools and ticket-buyer verification to better combat bots. In addition, 

a major search engine recently required enhanced disclosures from ticket 

resellers using its advertising platform. The disclosures are intended to protect 

consumers from scams and prevent potential confusion about who is selling the

tickets. 

View GAO-18-347. For more information, 

contact Michael Clements at (202) 512-8678 

or ClementsM@gao.gov

Why GAO Did This Study

Tickets for concerts, theater, and 

sporting events can be purchased—

typically online—from the original seller 

(primary market) or a reseller 

(secondary market). Some state and 

federal officials and others have raised 

issues about ticketing fees, the effect

of the secondary market on ticket 

prices, and the transparency and 

business practices of some industry 

participants. Event ticketing is not 

federally regulated. However, federal 

legislation enacted in 2016 restricts 

bots (ticket-buying software). Also, the 

Federal Trade Commission (FTC) has 

taken two enforcement actions related 

to deceptive marketing by ticket sellers 

under its broad FTC Act authority. 

GAO was asked to review issues 

around online ticket sales. This report 

examines (1) what is known about 

online ticket sales, (2) consumer 

protection issues related to such sales, 

and (3) potential advantages and 

disadvantages of selected approaches 

to address these issues. 

GAO focused on concert, theater, and 

major league sporting events for which 

there is a resale market. GAO 

analyzed data on fees, ticket volume, 

and resale prices from a variety of 

sources; reviewed the largest ticket 

sellers’ websites and purchase 

processes; and reviewed federal and 

state laws and relevant academic 

literature. GAO also interviewed and 

reviewed documentation from 

government agencies; consumer 

organizations; ticket sellers; venue 

operators; promoters and managers; 

sports leagues; and academics 

(selected for their experience and to 

provide a range of perspectives).
Page i GAO-18-347 Event Ticket Sales

Letter 1

Background 3

Ticketing Practices, Prices, Fees, and Resale Vary by Industry 

and Event 6

Consumer Protection Concerns Include the Ability to Access 

Face-Value Tickets and the Fees and Clarity of Some Resale 

Websites 18

Effects of Ticket Resale Restrictions and Disclosures on 

Consumers and Business Would Vary 36

Agency Comments 51

Appendix I Objectives, Scope, and Methodology 53

Appendix II GAO Contact and Staff Acknowledgments 58

Tables

Table 1: Key Participants in the Primary and Secondary Markets 

for Event Tickets 3

Table 2: Selected Research on Ticket Resale Prices and the 

Extent of Resale 13

Table 3: Observed Fees Charged by Three of the Largest Primary 

Ticketing Companies 17

Table 4: Fees Charged by Three of the Largest Ticket Resale 

Exchanges 18

Table 5: Potential Advantages and Disadvantages of Selected 

Legislative or Regulatory Actions Related to Ticket Resale 36

Figures

Figure 1: Hypothetical Example of White-Label Search Results 

and Website 26

Figure 2: Hypothetical Examples of How a Ticket Price and Fees 

Can Initially Be Displayed 43

Contents
Page ii GAO-18-347 Event Ticket Sales

Abbreviations

BOTS Act Better Online Ticket Sales Act of 2016

DOJ Department of Justice

FTC Federal Trade Commission

IP Internet protocol

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-18-347 Event Ticket Sales

441 G St. N.W.

Washington, DC 20548

April 12, 2018

The Honorable Greg Walden

Chairman

The Honorable Frank Pallone, Jr.

Ranking Member

Committee on Energy and Commerce

House of Representatives

The Honorable Bill Pascrell, Jr.

House of Representatives

The Honorable Fred Upton

House of Representatives

In recent years, consumers and others have raised issues about the 

online ticket marketplace for concerts, commercial theater, and sporting 

events.1 For example, some consumers have complained about difficulty 

obtaining face-value tickets for popular events at the primary, or initial, 

sale to the general public—only to find the tickets immediately available at 

high markups on the secondary, or resale, market. In response, event 

organizers and legislators have targeted ticket bots—automated software 

that ticket brokers can use to buy large volumes of tickets. The Better 

Online Ticket Sales Act of 2016 (BOTS Act) restricted the use of bots and 

gave the Federal Trade Commission (FTC) and state attorneys general 

the authority to pursue violators with civil actions.2 Other issues that have 

been raised include the amount of ticket fees and restrictions on 

transferring some tickets.

You asked us to review the marketplace and consumer protection issues 

related to online ticket sales. This report examines (1) what is known 

about primary and secondary online ticket sales, (2) the consumer 

protection concerns that exist related to online ticket sales, and (3) 

 1

For purposes of this report, we use “online” to refer to activity that occurs on a website or 

through a mobile application. Although this report focuses on online ticketing, in some 

cases the issues discussed could also apply to tickets purchased via telephone or at a 

physical location.

2

Better Online Ticket Sales Act of 2016, Pub. L. No. 114-274, 130 Stat. 1401 (2016) 

(BOTS Act).

Letter
Page 2 GAO-18-347 Event Ticket Sales

potential advantages and disadvantages of selected approaches to 

address these concerns.

To address the first objective, we obtained and analyzed data on ticket 

volume and resale prices obtained from ticket sellers’ websites for a 

nonprobability sample of 22 events, which were selected to represent a 

variety of event types and popularity levels. We collected data from 

October 16 through December 20, 2017. We also reviewed trade industry 

data on ticket prices and sales.

To address the second objective, we reviewed the websites of 6 primary 

market ticket sellers, 11 secondary ticket exchanges, and 8 ticket sellers 

using “white-label” websites.3 For a sample of 31 events, chosen to reflect 

a mix of event types and venue sizes (e.g., arenas, theaters), we 

reviewed the process of purchasing tickets online and documented when 

and how clearly fees and restrictions were disclosed. In addition, we 

assessed the accuracy of information that customer service departments 

of three large secondary ticket exchanges provided. We also reviewed 

relevant enforcement activity by federal and state agencies and obtained 

and analyzed summary complaint data from FTC’s Consumer Sentinel 

Network database.

To address the third objective, we reviewed federal and selected state 

laws and examined the experiences of three U.S. states (Connecticut, 

Georgia, and New York) with relevant event ticketing laws. We also 

reviewed foreign government reports to obtain information on relevant 

ticketing restrictions in two foreign countries (Canada and the United 

Kingdom) with similar consumer protection issues reviewed in this report. 

For all three objectives, we reviewed documentary evidence (such as 

academic studies, trade reports and databases, and industry literature) 

and interviewed staff from FTC, Department of Justice (DOJ), and three 

state offices of attorney general; consumer organizations; primary and 

secondary ticket sellers; venue operators, event promoters, and artists’

managers and agents; major sports leagues; and academics who have 

studied the ticket marketplace—all of whom were selected for their 

experience and to provide a range of perspectives. For more information 

on our scope and methodology, see appendix I.

 3

A white-label website is a sales website built by one company that allows affiliates to use 

the software to build their own, uniquely branded websites.
Page 3 GAO-18-347 Event Ticket Sales

We conducted this performance audit from November 2016 to April 2018, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. We conducted our related 

investigative work in accordance with investigative standards prescribed 

by the Council of the Inspectors General on Integrity and Efficiency.

The marketplace for primary and secondary ticketing services consists of 

several types of participants, including primary market ticketing 

companies, professional ticket brokers, secondary market ticket 

exchanges, and ticket aggregators (see table 1). Other parties that play a 

role in event ticketing, as discussed later in this report, include artists and 

their managers, booking agents, sports teams, producers, promoters, and 

operators of event venues (such as clubs, theaters, arenas, or 

stadiums).4

Table 1: Key Participants in the Primary and Secondary Markets for Event Tickets

Participant Description

Primary market ticketing 

companies

Companies that provide initial-sale ticketing services for 

events

Professional ticket brokers Companies or individuals who buy tickets, usually on the 

primary market, with the intention of reselling at a profit

Secondary market ticket 

exchanges

Online resale platforms that facilitate transactions 

between third parties (brokers or consumers), but 

generally do not maintain their own ticket inventory

Ticket aggregators Websites that aggregate in one place the resale listings 

from multiple secondary ticket exchanges

Source: GAO. | GAO-18-347

 4

Although the terms vary with use, “promoter” generally refers to a person or company 

that contracts with artists or their representatives to arrange events. Promoters also 

secure venues in which events will occur, arrange for production services, and market 

events to the public. “Producer” generally refers to a person or company that oversees all 

aspects of a theater production, including hiring creative staff (such as writers, directors,

composers, choreographers, and performers), securing financing and a venue, and 

promoting the event. For this report, we use “event organizers” to refer to a combination of 

artists, managers, booking agents, promoters or producers, and venue operators.

Background

The Ticketing Marketplace
Page 4 GAO-18-347 Event Ticket Sales

The private research firm IBISWorld estimated that online ticketing 

services (including ticketing for concerts, sporting events, live theater,

fairs, and festivals) represented a $9 billion market in 2017, which 

included both the primary and secondary markets.5 Another private 

research firm, Statista, estimated that U.S. online ticketing revenues for 

sports and music events totaled about $7.1 billion in 2017.6 Estimates of 

the total number of professional ticket sellers vary. IBISWorld estimated 

that the U.S. market for online event ticket sales included 2,571 

businesses in 2017. The Census Bureau lists more than 1,500 ticket 

services companies as of 2015 based on the business classification code 

for ticket services. However, this does not provide a reliable count of 

companies in the event ticketing industry because it includes companies 

selling tickets for services such as bus, airline, and cruise ship travel, 

among other services.

However, a small number of companies conducts the majority of event 

ticket sales. In the primary ticket market—where tickets originate and are 

available at initial sale—Ticketmaster is the largest ticketing company. 

DOJ estimated that Ticketmaster (whose parent company is now Live 

Nation Entertainment) held more than 80 percent of market share in 

2008, and it was still the market leader as of 2017.7 Less than a dozen 

other companies control most of the rest of the primary market, by our 

estimates. In the secondary market—where resale occurs—more 

companies are active, but StubHub estimated it held roughly 50 percent 

of market share as of 2017. According to Moody’s Investors Service, 

Ticketmaster, which in addition to its primary market ticketing has a U.S. 

resale subsidiary, held the second-largest market share as of 2016.

The majority of ticket sales occur online, through a website or mobile 

application. Ticketmaster’s parent company reported that 93 percent of its 

primary tickets were sold online in 2017.8 The industry research group 

 5

IBISWorld, Online Event Ticket Sales in the US.: Market Research Report, (December 

2017)

6

Statista, “Event Tickets,” accessed January 17, 2018, 

https://www.statista.com/outlook/264/109/event-tickets/united-states. 

7

Competitive Impact Statement, United States of America v. Ticketmaster Entertainment, 

Inc., No. 1:10-cv-00139 (D. D.C. Jan. 25, 2010); Live Nation Entertainment, Inc., Annual 

Report (Form 10-K) (Feb. 27, 2018). DOJ based its market share estimate on the number 

of major concert venues Ticketmaster served at the time.

8

Live Nation Entertainment, Inc. 2017 10-K. 
Page 5 GAO-18-347 Event Ticket Sales

LiveAnalytics reported that in 2014, 68 percent, 50 percent, and 49 

percent of people attending concerts, sporting events, and live theater or 

arts events, respectively, had recently purchased a ticket online.9

The event ticketing industry is not federally regulated. However, the 

Federal Trade Commission Act prohibits unfair or deceptive acts or 

practices in or affecting commerce, and FTC can enforce the act for 

issues related to event ticketing and ticketing companies.10 One federal 

statute specifically addresses ticketing issues—the BOTS Act, which 

prohibits, among other things, circumventing security measures or other 

systems intended to enforce ticket purchasing limits or order rules.11 The 

act also makes it illegal to sell or offer to sell any event ticket obtained 

through these illegal methods and granted enforcement authority to FTC 

and state attorneys general.12

The Department of Justice’s Antitrust Division plays a role in monitoring 

competition in the event ticketing industry. In 2010, Live Nation and 

Ticketmaster—respectively, the largest concert promoter and primary 

ticket seller in the United States—merged to form Live Nation 

Entertainment, Inc. DOJ approved the merger after requiring Ticketmaster 

to license its primary ticketing software to a competitor, sell off one 

ticketing unit, and agree to be barred from certain forms of retaliation 

against venue owners who use a competing ticket service. DOJ may also 

inspect Live Nation’s records and interview its employees to determine or 

secure compliance with the terms of the final judgment clearing the 

merger.13

State government agencies generally invoke state laws on unfair and 

deceptive acts and practices to address ticketing violations, according to 

representatives of two state attorney general offices. In addition, several 

states have laws that directly apply to event ticketing. For example, some 

 9

LiveAnalytics, U.S. Live Event Attendance Study, June 2014. These included ticket 

purchases from both primary and secondary market sources.

10See 15 U.S.C. § 45(a)(1) (2017); 15 U.S.C. § 45c (2017).

11BOTS Act, supra. 

12BOTS Act, §2(a)-(c). 

13United States of America v. Ticketmaster Entertainment, Inc., No. 1:10-cv-00139 

(D.D.C. July 30, 2010).

Regulation
Page 6 GAO-18-347 Event Ticket Sales

states restrict the use of bots, several other states impose price caps (or 

upper limits) on ticket resale prices, and states including Connecticut, 

New York, and Virginia restrict the use of nontransferable tickets (tickets 

with terms that do not allow resale). Several states require brokers to be 

licensed and adhere to certain professional standards, such as 

maintaining a physical place of business and a toll-free telephone 

number, and offering a standard refund policy.14

The concert, sports, and theater industries vary in how they price and 

distribute tickets. Many tickets are resold on the secondary market, 

typically at a higher price. Among a nongeneralizable sample of events 

we reviewed, we observed that primary and secondary market ticketing 

companies charged total fees averaging 27 percent and 31 percent, 

respectively, of the ticket’s price.

Ticketing practices for major concerts include presales and pricing that 

varies based on factors like location and the popularity of the performer. 

Tickets to popular concerts are often first sold through presales, which 

allow certain customers to purchase tickets before the general on-sale. 

Common presales include those for holders of certain credit cards or 

members of the artist’s fan club, although promoters, venues, or other 

groups also may offer presales. Credit card companies might provide free 

marketing for events or other compensation in exchange for exclusive 

early access to tickets for their cardholders. In addition, the artist usually 

has the option to sell a portion of tickets to its fan club. The venue’s 

ticketing company might want to limit the number of tickets allocated to 

fan clubs because the artist and manager can sell them through a 

separate ticketing platform, according to three event organizers we 

interviewed.

 14In addition to certain state requirements, at least 200 brokers belong to the National 

Association of Ticket Brokers, which requires its members to adhere to a code of ethics 

that includes a variety of customer service and consumer protection provisions. 

Ticketing Practices,

Prices, Fees, and 

Resale Vary by 

Industry and Event

On the Primary Market, 

Ticketing Practices Vary 

by Industry and Popular 

Events Are Sometimes 

Priced below Market

Concerts
Page 7 GAO-18-347 Event Ticket Sales

There are no comprehensive data on the proportion of tickets sold 

through presales because this information is usually confidential. Industry 

representatives told us that 10 percent to 30 percent of tickets for major 

concerts typically are offered through presales, although it can be as 

many as about 65 percent of tickets for major artists performing at large 

venues. In addition, fan club presales usually represent 8 percent of 

tickets, although it may be more if the fan club presale uses the venue’s 

ticketing company, according to two event organizers. A large ticketing 

company told us that 10 percent of tickets may be available for fan club 

presales. A 2016 study by the New York State Office of the Attorney 

General found that an average of 38 percent of tickets were allotted to 

presales for the 74 highest-grossing concerts at selected New York State 

venues in 2012–2015.15

Additionally, venues, promoters, agents, and artists commonly hold back 

a small portion of tickets from public sale. “Holds” may be given or sold to 

media outlets, high-profile guests, or friends and family of the artist. They 

also may be used to provide flexibility when the seating configuration is 

not yet final. Promoters typically will release unused holds before the 

event, offering the tickets to the public at face value.

As with presales, little comprehensive data exist on the proportion of 

tickets reserved for holds. Industry representatives told us holds typically 

represent a relatively small number of tickets—a few hundred for major 

events or perhaps a thousand for a stadium concert. The New York 

Attorney General report’s review of a sample of high-grossing New York 

State concerts found that approximately 16 percent of tickets, on average, 

were allocated for holds. Of those holds, many went to venue operators—

for example, one arena with around 21,000 seats usually received more 

than 900 holds per concert held there.

The average face-value ticket price in 2017 among the top 100 grossing 

concert tours in North America was $78.93, according to Pollstar.16

Concert ticket prices vary by city or day of the week, based on anticipated 

demand. The main parties involved in price setting are the artist and her 

 15New York State Office of the Attorney General, Obstructed View: What’s Blocking New 

Yorkers from Getting Tickets (New York, N.Y.: 2016). This figure included both fan club 

and credit card presales. Some of the concerts included multiple shows or tour stops by 

the same artist. 

16Pollstar, 2017 Year End Business Analysis (Fresno, Calif.: Pollstar, 2018). Pollstar is a 

trade publication covering the worldwide concert industry.
Page 8 GAO-18-347 Event Ticket Sales

or his management team, promoter, and booking agent. Venues 

sometimes provide input based on their knowledge of prevailing prices in 

the local market. Ticketing companies sometimes offer tools or support to 

help event organizers price tickets based on their analysis of sales trends.

Concert ticket prices are generally set to maximize profits, according to 

event organizers. In terms of production costs, the artist’s guarantee—the 

amount the artist is paid for each performance—is usually the largest 

expense. The most popular artists can command the highest guarantees 

and their concerts also tend to have the highest production costs.

However, for some high-demand events, tickets might be “underpriced”—

that is, knowingly set below the market clearing price that would provide 

the greatest revenue.17 Artists may underprice their tickets for a variety of 

reasons, according to industry stakeholders and our literature review:

• Reputation risk. Artists may avoid very high prices because they do 

not want to be perceived as gouging fans. Similarly, event organizers 

told us some artists have a certain brand or image—such as workingclass appeal—that could be harmed by charging very high ticket 

prices.

• Affordability. Some event organizers told us that artists want to price 

tickets below market to provide access to fans at all income levels.

• Sold-out show. Event organizers may price tickets lower to ensure a 

sold-out show, which can improve the artist and event organizers’

reputations and might help future sales.

• Audience mix. Some artists prefer to have the most enthusiastic fans 

at their shows, rather than just those able to pay the most, especially 

in the front rows, where tickets are generally the most expensive.

• Ancillary revenue. Better attendance through lower ticket prices can 

increase merchandise and concession sales, which can be a 

substantial source of revenue.

In addition, event organizers may unintentionally underprice concert 

tickets because of imperfect information about what consumers are willing 

 17For the purposes of this report, we consider high-demand events to be those for which 

tickets sell out early in the on-sale and prices are higher on the resale market. The market

clearing price refers to the price at which the number of tickets available for sale equals 

the number of tickets customers are willing to buy, resulting in neither a surplus nor a 

shortage.
Page 9 GAO-18-347 Event Ticket Sales

to pay. Tickets are also priced based on the prices and sales of the 

artist’s (or similar artists’) past tours, but demand can be hard to predict. 

Three event organizers told us that they have started using data from the 

ticket resale market to help set prices because that is a good gauge of the 

true market price.

For major league professional sports, most decisions about ticket pricing 

and ticket distribution are made by the individual teams rather than by the 

league.18 According to the three major sports leagues we interviewed, 

their teams generally sell most of their tickets through season packages, 

with the remainder sold for individual games. Teams favor packages 

because they guarantee a certain level of revenue for the season. 

Representatives of two major sports leagues told us that their teams sold 

an average of 85 percent and 55 percent, respectively, of their tickets 

through season packages. One league told us that some of its teams 

increasingly offer not only full-season packages, but also partial-season 

packages. Another league said that in some cases, its teams might need 

to reserve a certain number of single game-day tickets—for example, as 

part of an agreement when public funds helped build a new stadium.

Representatives of the three sports leagues we interviewed told us that 

their teams do not use presales and holds to the same extent as the 

concert industry. Although teams do not sell a significant number of 

tickets through presales, they might offer first choice of seats to season 

ticket holders or individuals who purchased tickets in the past. In terms of 

holds, one league told us it requires its teams to hold a small number of 

tickets for the visiting team and teams might also hold a few tickets for 

sponsors and performers. Another league told us it does not have leaguewide requirements on holds, but its teams sometimes hold a small 

number of seats for media.

Sports teams generally set their ticket prices to maximize revenue, based 

on supply and anticipated demand, according to the leagues we 

interviewed. Ticket prices typically vary year-to-year, based on factors 

such as the team’s performance the previous season and playing in a 

 18In this report, sporting events refer to games played by teams of the four largest 

professional sports leagues in the United States, which are Major League Baseball, the 

National Football League, the National Basketball Association, and the National Hockey 

League. 

Sporting Events
Page 10 GAO-18-347 Event Ticket Sales

new stadium.19 Teams in many leagues use “dynamic pricing” for 

individual game tickets. They adjust prices as the game approaches 

based on changing demand factors, such as team performance and the 

weather forecast. The sports leagues with whom we spoke said teams’

pricing considerations are based in part on a desire to have affordable 

tickets for fans of different income levels. In addition, one league told us 

its teams rely heavily on revenues other than ticket sales, such as from 

television deals and sponsorships.

Tickets for Broadway and national touring shows are distributed through 

direct online sales as well as several additional channels, including dayof-show discount booths, group packages, and call centers.20 Industry 

representatives told us that these shows use presales and holds, but not 

as extensively as the concert industry. At our request, a company 

provided us with data for five Broadway shows from June 2016 to 

September 2017.21 Approximately 13 percent of tickets in this sample 

were sold through presales, almost all of which were group sales (offered 

to particular groups prior to the general on-sale). Less than 1 percent of 

tickets in this sample were sold through presales offered to specific credit 

cardholders. Two shows in high demand held back an average of about 6 

percent of tickets, while the other three shows held back about 1 percent.

Producers and venue operators generally set prices, which are influenced 

by factors like venue capacity and the length of run needed to recoup 

expenses, according to industry representatives. According to the 

Broadway League, from May 22, 2017, to February 11, 2018, the average 

face-value price of a Broadway show was $123—an average of $127 for 

musicals and $81 for plays. Industry representatives told us they sell 

about 10 percent of tickets through day-of-show discount booths. Even 

the most popular shows typically offer steep discounts for a small number 

of tickets through lotteries or other means.

 19Patrick Rishe and Michael Mondello, “Ticket Price Determination in Professional Sports: 

An Empirical Analysis of the NBA, NFL, NHL, and Major League Baseball,” Sport

Marketing Quarterly, vol. 13, no. 2 (2004), 111. 

20In this report, theater refers to Broadway and national tours, which are generally 

commercial productions. We are excluding community and most nonprofit theater.

21We asked a company that collects data on Broadway ticketing to provide us with 

summary statistics on holds and presales for a small sample of shows that played in June 

2016 through September 2017, and to separate the results for high-demand shows 

(defined as selling 90 percent or more of available seats). The company selected and 

provided data on five shows, two of which were high-demand shows.

Theater
Page 11 GAO-18-347 Event Ticket Sales

Tickets for some of the most popular Broadway shows have sometimes 

been underpriced, according to Broadway theater representatives, who 

told us they feel obligated to maintain relatively reasonable prices and to 

allow consumers of varying financial resources to attend their shows. 

Additionally, some shows are underpriced because their popularity was 

not anticipated. At the same time, in recent years, producers have started 

charging much higher prices (sometimes exceeding $500) for premium 

seats or for shows in very high demand, which allows productions to 

capture proceeds that would otherwise be lost to the secondary market.

Sometimes event organizers work directly with brokers to distribute 

tickets on the secondary market. For high-demand events, event 

organizers may seek to capture a share of higher secondary market 

prices without the reputation risk of raising an event’s ticket prices 

directly. For lower-demand events, selling tickets directly to brokers can 

guarantee a certain level of revenue and increase exposure (by using 

multiple resale platforms rather than a single ticketing site).

• In major league sports, teams sell up to 30 percent of seats directly to 

brokers, according to a large primary ticket seller.

• For Broadway theater, one company told us it regularly distributes 

about 8 percent to 10 percent of its tickets to a few authorized 

secondary market brokers.

• In the concert industry, it is unclear how often artists and event 

organizers sell tickets directly through the secondary market. Any 

formal agreements would be in business-confidential contracts, 

according to industry representatives, and artists may be concerned 

about disclosing them for fear of appearing to profit from high resale 

prices.

All the artists’ representatives with whom we spoke denied that their 

clients sold tickets directly to secondary market companies. However, a 

Vice President of the National Consumers League has cited evidence of 

cases in which ticket holds reserved for an artist were listed on the 

secondary market.22 A representative of one secondary market company 

told us of two cases in which representatives of popular artists 

 22Legislative Hearing on 17 FTC Bills, House of Representatives, Energy and Commerce 

Committee, Subcommittee on Commerce, Manufacturing, and Trade, 114th Cong. 187-

198 (May 24, 2016) (statement of John Breyault, Vice President, Public Policy, 

Telecommunications, and Fraud; National Consumers League).

Relationships between Event 

Organizers and Brokers
Page 12 GAO-18-347 Event Ticket Sales

approached his company about selling blocks of tickets for upcoming 

tours.

Ticket resale prices can be significantly higher than primary market prices 

and brokers account for most sales on major ticket exchanges. When 

tickets on the primary market are priced below market value—that is, 

priced less than what consumers are willing to pay—it creates greater 

opportunities for profit on the secondary market. Resale transactions 

typically occur on secondary ticket exchanges—websites where multiple 

sellers can list their tickets for resale and connect with potential buyers. 

Primary ticketing companies have also entered the resale market. For 

example, Ticketmaster allows buyers to resell tickets through its TM+ 

program, which lists resale inventory next to primary market inventory, 

and it owns the secondary ticket exchange TicketsNow.com.

Generally speaking, the secondary market serves two types of sellers: (1) 

those who buy or otherwise obtain tickets with the intent of reselling them 

at a profit (typically, professional brokers), and (2) individuals trying to 

recoup their money for an event they cannot attend (or sports season 

ticket holders who do not want to attend all games or use resale to 

finance part of their season package). Representatives from the four 

secondary ticket exchanges with whom we spoke each said that 

professional brokers represent either the majority or overwhelming 

majority of ticket sales on their sites.

Sellers set their own prices on secondary ticket exchanges, but some 

exchanges offer pricing recommendations. The exchanges allow 

adjustment of prices over time, and sellers can lower prices if tickets are 

not selling, or raise prices if demand warrants. Software tools exist that 

assist sellers in setting prices and in automatically adjusting prices for 

multiple ticket listings.

However, resale prices are not always higher than the original price, and 

thus brokers assume some risk. In some cases, the market price declines 

below the ticket’s face value—for example, for a poorly performing sports 

team. The leading ticket exchange network has publicly stated that it 

estimates that 50 percent of tickets resold on its site sell for less than face 

value. However, we were unable to obtain data that corroborated this 

statement.

Relatively few studies have looked at the ticket resale market for major 

concert, sporting, or theatrical events. Our review of relevant economic 

Tickets to Popular Events 

Are Often Resold on the 

Secondary Market at 

Prices above Face Value
Page 13 GAO-18-347 Event Ticket Sales

literature identified six studies that looked at ticket resale prices, one of 

which also looked at the extent of resale (see table 2). In general, the 

studies found a wide range of resale prices, perhaps reflecting the 

different methodologies and samples used or the limited amount of 

information on ticket resale. Additionally, the data reported are several 

years old and will not fully reflect the current market.

Table 2: Selected Research on Ticket Resale Prices and the Extent of Resale

Findings

Study title Author and source Study description Ticket prices Extent of resale

“Resale and RentSeeking: An 

Application to Ticket 

Markets”

Phillip Leslie and 

Alan Sorenson, The 

Review of Economic 

Studies, vol. 81, no. 

1 (2013)

Using a sample of 56 concerts for 

popular artists in 2004, the study 

compared the number of tickets and 

resale prices from a major secondary 

ticket exchange and an online auction 

site to the number of tickets sold and 

prices in the primary market.

Seventy-four percent of 

tickets were resold above 

face value and 26 percent 

of tickets were resold below 

face value. The average 

resale price overall was 41 

percent higher than the 

face-value price.

On average, about 

5 percent of tickets 

were resold, with a 

range among 

concerts of 3–17 

percent.

“Obstructed View: 

What’s Blocking New 

Yorkers from Getting 

Tickets”

New York State 

Office of the 

Attorney General 

(2016)

Reviewed data from six brokers on 

90,000 sales transactions made from 

2010–2014 that showed the prices at 

which the brokers purchased and 

resold the tickets.

On average, the resale 

price was 49 percent higher 

than the face-value price. 

By broker, the average 

markup ranged from 15 

percent to 112 percent.

Not addressed 

(n/a).

“Primary-Market 

Auctions for Event 

Tickets: Eliminating 

the Rents of ‘Bob the 

Broker’?”

Aditya Bhave and 

Eric Budish, NBER 

Working Paper No. 

23770 (National 

Bureau of Economic 

Research, 

Cambridge, Mass., 

2017)

Reviewed face-value and resale 

prices of tickets to 576 concerts in 

2007 and 2008. Looking at the best 

seats sold using auctions, the study 

compared the tickets’ original facevalue prices to initial-sale (by auction)

prices and secondary market prices.

Secondary market prices, 

which were close to the 

auction prices, were about 

double the tickets’ facevalue prices.

n/a

“An Examination of 

Dynamic Ticket 

Pricing and 

Secondary Market 

Price Determinants in 

Major League 

Baseball”

Stephen L. Shapiro 

and Joris Drayer,

Sport Management 

Review, vol. 17, no. 

2 (2014)

Looking at 12 games in a Major 

League Baseball team’s 2010 

season, the study compared the 

tickets’ face-value prices and season 

ticket holder prices to listed prices on 

a major secondary ticket exchange.

The average listed resale 

price was 103 percent 

higher than the average 

price paid by season ticket 

holders and about 45 

percent higher than the 

average single game-day 

price.a

n/a

“An Examination of 

Underlying 

Consumer Demand 

and Sport Pricing 

Using Secondary 

Market Data”

Joris Drayer, Daniel 

A. Rascher, and 

Chad D. McEvoy, 

Sport Management 

Review, 15 (2012).

The study compared the secondary 

market sale price to the primary 

market price for all 32 NFL teams in 

the 2007– 2008 season.

The average secondary 

market price was 143 

percent higher than the 

average primary market 

price. 

n/a
Page 14 GAO-18-347 Event Ticket Sales

Findings

Study title Author and source Study description Ticket prices Extent of resale

“Pricing Behavior in 

Perishable Goods 

Markets: Evidence 

from Secondary 

Markets for Major 

League Baseball 

Tickets”

Andrew Sweeting, 

Journal of Political 

Economy, 120, no. 

6 (2012).

The study compared 2007 ticket 

prices for the home games of 29 

Major League Baseball teams to 

listed prices on a major resale 

exchange and online auction site.

The average listed resale 

price was about twice the 

corresponding face-value 

price, although prices 

declined as game-day 

approached.a

n/a

Source: GAO-selected research. | GAO-18-347

a

“Listed” resale price refers to the price listed and not necessarily to the price at which the ticket 

actually sold.

For illustrative purposes, we reviewed secondary market ticket availability 

and prices for a nongeneralizable sample of 22 events.23 Among our 

selected events, the proportion of seats that were listed for resale ranged 

from 3 percent to 38 percent. In general, among the 22 events we 

reviewed, listed resale prices tended to be higher than primary market 

prices. For example, tickets for one sold-out rock concert had been about 

$50 to $100 on the primary market but ranged from about $90 to $790 in 

secondary market listings.

For 7 of the 22 events, we observed instances in which tickets were listed 

on the resale market even when tickets were still available from primary 

sellers at a lower face-value price.24 For example, one theater event had 

secondary market tickets listed at prices ranging from $248 to $1,080 

(average of $763), while a substantial number of tickets for comparable 

seats were still available on the primary market at $198 to $398.25 We did 

 23We reviewed data from two ticket resale sites for a sample of 22 events, 17 of which we 

categorized as high-demand. We also reviewed data from the primary ticket market for 

each event. We defined high-demand events as those that were likely to sell out, which 

we assessed by reviewing past attendance at other events for the same artist, sports 

team, or theatrical event. We focused on high-demand events because they have been 

the focus of interest in issues regarding resale activity. For each event, we determined (1) 

the proportion of tickets listed on the secondary market, and (2) how listed resale prices 

compared to face-value prices. Events were selected to represent concert, sporting, and 

theater events at different demand levels (popular versus other events). We collected data 

between October 16 and December 20, 2017. 

24We did not have information on how many tickets were available at various price points 

and it is possible that the differences in pricing could have been due to the number or 

quality of seats on the primary market.

25To combine data from the two resellers, we computed median weekly ticket prices for 

each event from each vendor, and then computed an average weighted by the number of 

available tickets on each website. The primary and secondary market prices do not 

include fees.
Page 15 GAO-18-347 Event Ticket Sales

not have data to determine whether the resale tickets actually sold at their 

listed price. However, as discussed later, it is possible that some 

consumers buy on the secondary market, at a higher price, because they 

are not aware that they are purchasing from a resale site rather than the 

primary seller.

Ticket fees vary in amount and type among the primary and secondary 

markets, and among different ticketing companies and events.

Companies that provide ticketing services on the primary market typically 

charge fees to the buyer that are added to the ticket’s list price and can 

vary considerably. A single ticket can have multiple fees, commonly 

including a “service fee,” a per-order “processing fee,” and a “facility fee”

charged by the venue. Most primary ticketing companies offer free 

delivery options, such as print-at-home or mobile tickets, but charge 

additional fees for delivery of physical tickets.

Venues usually have an exclusive contract with a single ticketing 

company and typically negotiate fees for all events at the venue, though 

in some cases they do so by category of event. Ticketing companies and 

venues usually share fee revenue and in some cases, the venue receives 

the majority of the fee revenue, according to primary ticketing 

companies.26 In addition, event organizers told us that promoters 

occasionally negotiate with the venue to add ticket fees or receive fee 

revenue.

Ticketing companies told us that they do not have a set fee schedule and 

amounts and types of fees vary among venues. Fees can be set as a 

fixed amount, a fixed amount that varies with the ticket’s face value (for 

 26Ticketing companies earn revenue from tickets they sell through their website, mobile 

application, call center, or physical outlets. However, they typically do not earn any fee 

revenue from season tickets or tickets sold through the venue box office, or through the 

artists’ fan clubs when the fan club tickets are sold on a third-party ticketing company’s 

platform.

Total Ticket Fees 

Averaged 27 Percent on 

the Primary Market and 31 

Percent on the Secondary 

Market for Events We 

Reviewed

Primary Market Fees
Page 16 GAO-18-347 Event Ticket Sales

example, $5 for tickets below $50 and $10 for tickets above $50), a 

percentage of face value, or other variations.

While ticketing fees vary considerably, the 2016 New York Attorney 

General report found average ticket fees of 21 percent based on its 

review of ticket information for more than 800 tickets at 150 New York 

State venues.27 (In other words, a ticketing company would add $21 in 

fees to a $100 ticket, for a total price to the buyer of $121.) The 21 

percent figure encompassed all additional fees, including service fees and 

flat fees, like delivery or order processing fees.

We conducted our own review of ticketing fees for a nongeneralizable 

sample of a total of 31 concert, theater, and sporting events across five 

primary ticket sellers’ websites:28

• In total, the combined fees averaged 27 percent of the ticket’s face 

value, and we observed values ranging from 13 percent to 58 

percent.29

• Service fees were, on average, 22 percent of the ticket’s face value, 

and we observed values ranging from 8 percent to 37 percent.

• Fourteen of the events we reviewed had an additional order 

processing fee, ranging from $1.00 to $8.20.

• Five of the events we reviewed had an additional facility fee, ranging 

from $2.00 to $5.10.

Table 3 shows the ticketing fees observed for events sold through three 

of the largest ticket companies we reviewed.

 27New York State Office of the Attorney General, 29, 41. The report collected fee 

information and ticket prices for 150 New York venues listed on three primary ticketing 

websites. For each venue, fee information was collected for up to three randomly selected 

events and, for each event, information was collected for every seating category (e.g., 

orchestra, balcony). 

28A GAO investigator and a GAO analyst collected data between June 19, 2017, and 

January 16, 2018 on the ticket fees charged for online purchase by five primary ticketing 

companies. From one to three concert, theater, and sporting events were reviewed for 

each company, covering 12 events and 10 venues in total. Ticket fees were also reviewed 

for an additional 20 events sold by the largest ticketing company.

29These totals encompassed both fees that were charged as a percentage of face value 

(such as “service” fees) and fixed-dollar fees (such as “order processing” fees).
Page 17 GAO-18-347 Event Ticket Sales

Table 3: Observed Fees Charged by Three of the Largest Primary Ticketing 

Companies 

Company

Service fee charged to 

buyer (as a percent of 

the face value) Facility fee

Order 

processing fee

Ticket company A 23–27% None observed $1.00

Ticket company B 19–27% $2.00 None observed

Ticket company C 8–37% $2.85–$5.10 $3.92–$8.20

Source: GAO analysis of primary ticket sellers’ websites. | GAO-18-347

Notes: Not every ticket we observed had a facility fee or an order processing fee. In total, we 

observed 28 events from these three companies.

A sixth ticketing company that focuses on theater uses a different fee 

structure. It simply charges two flat service fees across all of its events 

($7 for tickets below $50 and $11 for tickets above $50), plus a base perorder handling charge of $3. Additionally, we noted that the 6 sporting 

events we observed tended to have lower fees than the 16 concerts and 

9 theater events we observed. Specifically, sporting events had total fees 

averaging roughly 20 percent, compared to about 30 percent for concerts 

and theater.

Fees charged by secondary ticket exchanges we reviewed were higher 

than those charged by primary market ticket companies.30 Secondary 

ticket exchanges often charge service and delivery fees to ticket buyers 

on top of the ticket’s listed price. For 7 of the 11 secondary ticket 

exchanges we reviewed, the service fee was a set percentage of the 

ticket’s list price. Three of the remaining exchanges charged fees that 

varied across events, and the fourth did not charge service fees. Among 

the 10 exchanges that charged fees:

• In total, the combined fees averaged 31 percent of the ticket’s listed 

price, and we observed values ranging from 20 percent to 56 percent.

• Service fees, on average, were 22 percent of the ticket’s listed price, 

and we observed values ranging from 15 percent to 29 percent.

 30A GAO investigator and a GAO analyst gathered information on fees charged for seven 

events on the websites of 11 secondary market ticketing companies, which included nine 

ticket exchanges and two aggregators of ticket resale websites. For each website, from 

three to five events were reviewed, which included at least one concert, theater, and 

sporting event per site. 

Secondary Market Fees
Page 18 GAO-18-347 Event Ticket Sales

• In addition to the service fee, 8 of the 10 exchanges charged a 

delivery fee for mobile or print-at-home tickets, ranging from $2.50 to 

$7.95.

• Eight of the exchanges also charged a fee to the seller (in addition to 

the buyer), which was typically 10 percent of the ticket’s sale price. 

(For example, if a ticket sells for $100, the seller would receive $90 

and the exchange $10.)

Table 4 provides additional information about the fees charged by three of 

the largest ticket resale exchanges.

Table 4: Fees Charged by Three of the Largest Ticket Resale Exchanges 

Exchange

Service fee charged to buyer 

(as a percent of ticket price) Delivery fee charged to buyer

Fee charged to seller (as a 

percent of ticket price)

Resale exchange A 10–25% Download: $2.50 or $7.95

Mail: $14.95

0–10%

Resale exchange B 21–24% None 10%

Resale exchange C 29–30% Download: $7.95

Mail: $15.00

0–10%

Source: GAO review of secondary ticket exchange websites. | GAO-18-347

Note: We observed three events per resale exchange. For resale exchanges A and C, data were 

obtained both from our observations and from communication with company officials.

The technology and other resources of professional brokers give them a 

competitive advantage over individual consumers in purchasing tickets at 

their face-value price. Views vary on the extent to which the use of holds 

and presales also affect consumers. Many ticketing websites we reviewed 

did not clearly display their fees up front, and a subset of websites—

referred to as white-label—used marketing practices that might confuse 

consumers. Other consumer protection concerns that have been raised 

involve the amount charged for ticketing fees, speculative and fraudulent 

tickets, and designated resale exchanges (resale platforms linked to the 

primary ticket seller).

Tickets to popular events often are not available to consumers at their 

face-value price, frequently because seats sell out in the primary market 

almost as soon as the venue puts them on sale.

Consumer Protection 

Concerns Include the 

Ability to Access 

Face-Value Tickets 

and the Fees and 

Clarity of Some 

Resale Websites

For Tickets to Popular 

Events, Consumers Often 

Must Pay More Than Face 

Value
Page 19 GAO-18-347 Event Ticket Sales

Brokers whose business is to purchase and resell tickets have a 

competitive advantage over individual consumers because they have the 

technology and resources to purchase large numbers of tickets as soon 

as they go on sale. Some consumer advocates, state officials, and event 

organizers believe that brokers unfairly use this advantage to obtain 

tickets from the primary market, which restricts ordinary consumers from 

buying tickets at face value. As a result, consumers may pay higher 

prices than they would if tickets were available on the primary market. In 

addition, some event organizers and primary ticket sellers have 

expressed frustration that the profits from the higher resale price accrue 

to brokers who have not played a role in creating or producing the event.

Some professional brokers use software programs known as bots to 

purchase large numbers of tickets very quickly. When tickets first go on 

sale, bots can complete multiple simultaneous searches of the primary 

ticket seller’s website and reserve or purchase hundreds of tickets, 

according to the 2016 report by the New York State Office of the Attorney 

General.31 Seats reserved by a bot—even if ultimately not purchased—

appear online to a consumer as unavailable. This, in turn, can make 

inventory appear artificially low during the first minutes of the sale and 

lead consumers to the secondary market to seek available seats, 

according to event organizers we interviewed.32 Bots can also automate 

the ticket-buying process, as well as identify when additional tickets are 

released and available for purchase. During its investigation of the 

ticketing industry, the New York State Office of the Attorney General 

identified an instance in which a bot bought more than 1,000 tickets to a 

single event in 1 minute.33

 31New York State Office of the Attorney General, 15. We did not identify comprehensive 

information on the prevalence of the use of bots in purchasing event tickets. 

Representatives from one primary ticketing company told us it believes bots accounted for 

21 percent of online ticket inquiries (i.e., attempts to access the system and not 

necessarily actual purchases) for two high-demand shows over a 3 month period (which it 

identified based on certain characteristics associated with bot use). Other ticket sellers 

with whom we spoke said they believe bots are still widely used, especially for the most 

popular events. However, one said it did not have a reliable estimate on the use of bots, 

noting that they do not have any way of being certain whether or not a bot was used to 

purchase a ticket.

32Primary ticket sellers typically limit the amount of time buyers have to complete a 

purchase—for example, 10 minutes from selecting tickets to completing payment. During 

this time, the selected tickets are removed from the inventory and appear to other buyers 

to be unavailable.

33New York State Office of the Attorney General, 18.

Brokers’ Competitive 

Advantage
Page 20 GAO-18-347 Event Ticket Sales

In addition, bots can be used to bypass security measures that are 

designed to enforce ticket purchase limits. For example, bots can use 

advanced character recognition to “read” the characters in a test 

designed to ensure that the buyer is human.34 Although the BOTS Act of 

2016 restricts the use of bots, as discussed later, it is not yet clear the 

extent to which the act has reduced their use.

Brokers have other advantages over consumers in the ticket buying 

process, according to the New York State Attorney General’s report and 

industry stakeholders we interviewed. For example, some brokers employ 

multiple staff, who purchase tickets as soon as an event goes on sale. In 

addition, brokers can bypass sellers’ limits on the number of tickets 

allowed to be purchased by using multiple names, addresses, credit card 

numbers, or IP (Internet protocol) addresses.35 Finally, to access tickets 

during a presale, some brokers join artists’ fan clubs or hold multiple 

credit cards from the company sponsoring the presale.

Holds and presales may limit the number of tickets available to 

consumers at face value, according to some consumer groups, 

secondary market companies, and other parties. For example, the 

National Consumers League testified that events with many holds and 

presales sell out more quickly during the general on-sale because fewer 

seats are available.36 Consumers may not be aware that many seats are 

no longer available by the time of the general on-sale. In addition, the 

National Consumers League and New York State Office of the Attorney 

General said they believe the use of holds and presales raise concerns 

about equity and fairness. They noted that most holds go to industry 

insiders who have a connection to the promoter or venue, while credit 

card presales are available only to cardholders, who typically are higher-

 34A common security measure is the Completely Automated Public Turing test to tell 

Computers and Humans Apart, commonly known as CAPTCHA, which asks users to 

prove they are human by identifying characters in distorted text or by selecting images 

that meet certain requirements (“Identify all photos with a car”). In some cases, bots are 

programmed to bypass this test. In other cases, the bot submits images of the tests to 

human workers who complete it, according to the report of the New York State Office of 

the Attorney General.

35Ticketing companies often limit the number of tickets a consumer can purchase during a 

single transaction. An Internet protocol (IP) address is a unique string of numbers that 

identifies each computer using the Internet to communicate over a network. 

36Breyault, 2, 5. The National Consumers League is a nonprofit consumer advocacy 

organization.

Role of Holds and Presales
Page 21 GAO-18-347 Event Ticket Sales

income. The New York State Attorney General’s office and seven event 

organizers with whom we spoke expressed concerns that presales benefit 

brokers, who take special measures to access tickets during presales.

However, other industry representatives told us that holds and presales 

do not adversely affect consumers. They noted that for most events, the 

number of tickets sold through presales is not very high and few tickets 

are held back. Additionally, two event organizers and representatives 

from a primary ticketing company noted that most presales are accessible 

to a broad range of consumers—such as tens of millions of cardholders. 

As a result, the distinction between what constitutes a presale and a 

general on-sale can be slim. Furthermore, some fan clubs may try to limit 

brokers’ use of presales. For example, one manager said his artist’s fan 

club gives priority for presales to long-time fan club members.

In addition, some industry representatives noted that holds and presales 

serve important functions that can benefit consumers. For example, credit 

card presales can reduce event prices by funding certain marketing costs, 

and fan club presales can offer better access to tickets to artists’ most 

enthusiastic fans, according to event organizers with whom we spoke. 

And as noted earlier, holds serve various functions, such as providing 

flexibility for seating configuration.

Among the largest primary and several secondary market ticketing 

companies, we identified instances in which fee information was not fully 

transparent. We reviewed the ticket purchasing process for a selection of 

primary and secondary ticketing companies’ websites, including a subset 

of secondary market websites known as “white-label” websites. We 

reviewed the extent to which the companies’ websites clearly and 

conspicuously presented their fees and other relevant information and 

also recorded the point at which fees were disclosed in the purchase 

process.37 While FTC staff guidance states that there is no set formula for 

a clear and conspicuous disclosure, it states that among several key 

factors are whether the disclosure is legible, in clear wording, and 

proximate to the relevant information.38 In recent reports, the National 

 37We did not, however, conduct a legal compliance review for these disclosures and we 

do not offer an opinion as to whether any of our findings about selected websites would 

meet the relevant FTC standard for unfair or deceptive practices.

38Federal Trade Commission, .com Disclosures: How to Make Effective Disclosures in 

Digital Advertising (March 2013) (staff guidance).

Some Ticketing Websites 

We Reviewed Were Not 

Fully Transparent about 

Ticket Fees and Relevant 

Disclosures
Page 22 GAO-18-347 Event Ticket Sales

Economic Council (which advises the President on economic policy) and 

FTC staff have expressed concern about businesses that use “drip 

pricing,” the practice of advertising only part of a product’s price up front 

and revealing additional charges later as consumers go through the 

buying process.39

For the 23 events we reviewed, the largest ticketing company—believed 

to have the majority of the U.S. market share—frequently did not display 

its fees prominently or early in the purchase process.40

• For 14 of 23 events we reviewed, fees could be learned only by (1) 

selecting a seat; (2) clicking through one or two additional screens; (3) 

creating a user name and password (or logging in); and (4) clicking an 

icon labeled “Order Details,” which displayed the face-value price and 

the fees.

• For 5 of the 23 events, the customer did not have to log in to see the 

fees, but the fees were visible only by clicking the “Order Details” icon.

• For 4 of the 23 events, fees were displayed before log-in and without 

the need to take additional steps.

• Additionally, for 21 of the 23 events, ticket fees were displayed in a 

significantly smaller font size than the ticket price.

For the five other primary market ticketing companies whose ticketing 

process we reviewed, fees were displayed earlier in the purchase process 

and more conspicuously.41 All five companies displayed fees before 

asking users to log in, including one that displayed fees during the initial 

seat selection process. Four of the five companies displayed fees in a 

font size similar to that of other price information and in locations on the 

page that were generally proximate to relevant information. However, for 

 39White House National Economic Council, The Competition Initiative and Hidden Fees 

(Washington, D.C.: December 2016); and Mary W. Sullivan, Economic Analysis of Hotel 

Resort Fees (Washington, D.C.: January 2017), Federal Trade Commission Bureau of 

Economics Staff Report.

40We reviewed the purchase process on the company’s website for 23 events, which 

included events at 13 different venues of varying sizes, including arenas and theaters. We 

collected data between June 20, 2017, and January 16, 2018. 

41For each of these five ticketing companies, a GAO investigator and a GAO analyst 

reviewed the purchase process for between one and three events. We believe these 

ticketing companies are among the largest in the U.S. 

Primary Market Ticketing 

Companies
Page 23 GAO-18-347 Event Ticket Sales

all companies we reviewed, fees and total ticket prices were not displayed 

during the process of browsing for different events.

We found that two primary ticket sellers that sometimes offer 

nontransferable tickets (that is, tickets whose terms and conditions 

prohibit transfer) had prominently and clearly disclosed the special terms 

of those tickets—for example, that the buyer’s credit card had to be 

presented at the venue and the entire party had to enter at the same 

time.42 One company’s website displayed these conditions on a separate 

screen for 10 seconds before allowing the buyer to proceed. The other 

company’s website similarly displayed information about the tickets’

nontransferability on a separate page in clear language in a font size 

similar to the pricing information.

We also reviewed disclosure of fees and other relevant information on the 

websites of 11 secondary ticket exchanges and resale aggregators.43

Two of the 11 websites displayed their fees conspicuously and early in 

the purchase process, and a third site did not charge ticketing fees. 

However, we found that ticket resale exchanges sometimes lacked 

transparency about their fees:

• Fees often were revealed only near the end. Seven of the 11 

websites disclosed ticket fees only near the end of the purchase 

process, after the consumer entered an e-mail or logged in. Three of 

those seven websites displayed fee information only after the credit 

card number or other payment information was submitted.

• Fees sometimes were not conspicuously located. On 2 of the 11 

websites, some fees were not displayed alongside the ticket price, but 

instead were only visible by clicking a specific button.

• Font sizes were small in two cases. On 2 of the 11 websites, fees 

were displayed in a font size significantly smaller than other text.

 42According to industry stakeholders, nontransferable tickets are rarely used. Due to their

rarity, we could only identify one event using nontransferable tickets from each of two 

ticket sellers at the time of our analysis.

43The 11 companies included 9 secondary ticket exchanges and 2 ticket resale 

aggregators, which aggregate listings from multiple exchanges. For each, we reviewed the 

purchase process for between three and five events.

Secondary Ticket Exchanges
Page 24 GAO-18-347 Event Ticket Sales

In contrast to primary market sellers, secondary market sellers’ websites 

sometimes did not clearly disclose when a ticket was nontransferable.44

Disclosures on secondary market ticket exchanges varied, in part 

because individual sellers are permitted to enter their own descriptions 

about ticket characteristics. In some cases, the seller identified 

nontransferable tickets only by labeling them “gc,” indicating that a gift 

card would be mailed to the buyer to present for entry to the venue.45

To further review nontransferable ticket listings, we contacted the 

customer service representatives of three large secondary ticket 

exchanges to ask about a nontransferable ticket listing.46 We asked if we 

would have difficulty using the ticket because the venue’s or ticket seller’s 

website stated that only the original buyer could use the ticket, with one 

website noting that picture identification might be required for entry. 

Customer service representatives of all three exchanges told us that 

despite the purported restrictions, we would be able to use the ticket to 

gain entry to the venue. To confirm these statements, we contacted 

officials of these venues, who acknowledged that picture identification 

had not been required for entry at these events.

Consumers may not always be aware they are purchasing tickets from a 

secondary market site at a marked-up price. In a 2010 enforcement 

action, FTC settled a complaint against Ticketmaster after alleging, 

among other things, that the company steered consumers to its resale 

site, TicketsNow, without clear disclosures that the consumer was being 

directed to a resale website. The settlement requires Ticketmaster, 

TicketsNow, and any other Ticketmaster resale websites to clearly and 

conspicuously disclose when a consumer is on a resale site and that 

prices may exceed face value, and to include “reseller price” or “resale 

price” with ticket listings. In addition, in January 2018, the National 

Advertising Division, a self-regulatory organization, asked FTC to 

 44According to some industry stakeholders, nontransferable tickets are sometimes resold, 

although the tickets’ terms and conditions prohibit it. 

45Because nontransferable tickets often require the buyer’s credit card or other 

identification be presented at the venue, brokers will sometimes purchase tickets using a 

prepaid card that is mailed to the buyer.

46For two of the companies, a GAO investigator and a GAO analyst sent eight e-mails to 

each customer service department. For the third company, five “live chats” were 

conducted with customer service representatives. Each e-mail or live chat inquired about 

one of two events using nontransferable tickets. We did not identify ourselves as 

representing GAO during these contacts.
Page 25 GAO-18-347 Event Ticket Sales

investigate the fee disclosure practices of StubHub, a large secondary 

ticket exchange, alleging the company did not clearly and conspicuously 

disclose its service fees when it provides ticket prices.47

A subset of ticket resale websites, known as “white label,” used marketing 

practices that might confuse consumers. A company providing white-label 

support allows affiliates to connect its software to their own, uniquely 

branded website.48 This is sometimes also described as a “private label”

service in the industry. For event ticketing, a ticket exchange offering 

white-label support provides the affiliate company with access to its ticket 

inventory and services, such as order processing and customer service. 

However, the affiliate uses its own URL (website address), sets the ticket 

prices and fees, and conducts its own marketing and advertising. Two 

secondary ticket exchanges operate white-label affiliate programs, under 

which affiliates create unique white-label websites for ticket resale.

While we did not identify data on the number of white-label websites for 

event ticketing, they commonly appear in the search results for all types 

of venues, including smaller venues like clubs and theaters. White-label 

websites often market themselves through paid advertising on Internet 

search engines, appearing at the top of search results for venues. Thus, 

they are often the first search results consumers see when searching for 

event tickets.49 Figure 1 provides a hypothetical example of a white-label 

 47The National Advertising Division is an investigative unit of the Council of Better 

Business Bureaus’ Advertising Self-Regulatory Council. According to an Advertising SelfRegulatory Council press release, StubHub declined to comply with the division’s previous 

recommendations, stating that its fee disclosure practices were in line with industry 

practice and that consumers generally understand that fees will be added at the end of the 

purchase process. See Advertising Self-Regulatory Council, “NAD Refers StubHub Pricing 

Claims to FTC for Further Review After Advertiser Declines to Comply with NAD Decision 

on Disclosures” news release, January 16, 2018, 

http://www.asrcreviews.org/nad-refers-stubhub-pricing-claims-to-ftc-for-further-review-after

-advertiser-declines-to-comply-with-nad-decision-on-disclosures/.

48White-label programs are used in many industries, not just event ticketing. For example, 

there are white-label software search engines for booking airlines and hotels. 

49Two of the largest search engines offer advertising services that allow companies to 

appear in the search results related to selected products or services. Advertisers identify 

keywords relevant to their products and when users search for those keywords, their 

advertisements will appear on top of or next to the relevant search results. These 

advertised search results are usually identified in some manner to separate them from 

other search results. Use of paid search results for event ticketing is not limited to whitelabel websites and is a common marketing practice of many primary and secondary 

market ticket sellers.

White-Label Websites for 

Ticket Resale
Page 26 GAO-18-347 Event Ticket Sales

advertisement on a search engine, as well as the typical appearance of a 

white-label website.

Figure 1: Hypothetical Example of White-Label Search Results and Website

Note: “GAO Arena” is a fictitious venue used for illustrative purposes.

In 2014, FTC and the State of Connecticut announced settlements with 

TicketNetwork—one of the exchanges operating a white-label program—

and two of its affiliates after charges of deceptively marketing resale 

tickets.50 The complaint alleged that these companies’ advertisements 

 50See Federal Trade Commission v. TicketNetwork, Inc., No. 3:14-cv-1046 (D. Conn. Aug. 

12, 2014); Federal Trade Commission v. SecureBoxOffice, LLC, No. 3:14-cv-1046 (D. 

Conn. Aug. 12, 2014); Federal Trade Commission v. Ryadd, Inc., No. 3:14-cv-1046 (D. 

Conn. Aug. 12, 2014).
Page 27 GAO-18-347 Event Ticket Sales

and websites misled consumers into thinking they were buying tickets 

from the original venue at face value when they were actually purchasing 

resale tickets at prices often above face value. According to the 

complaint, the affiliate websites frequently used URLs that included the 

venue’s name and displayed the venue’s name prominently on their 

websites in ways that could lead consumers to believe they were on the 

venue’s website. The settlements prohibited the company and its affiliates 

from misrepresenting that they are a venue website or that they are 

offering face-value tickets, and from using the word “official” on the 

websites, advertisements, and URLs unless the word is part of the event, 

performer, or venue name. They also required that the websites disclose 

that they are resale marketplaces, that ticket prices may exceed the 

ticket’s face value, and that the website is not owned by the venue or 

other event organizers.

FTC staff with whom we spoke told us that they were aware that similar 

practices have continued among other white-label companies. Staff told 

us they have continued to monitor white-label websites and related 

consumer complaints. Additionally, a wide range of stakeholders with 

whom we spoke—including government officials, event organizers, and 

other secondary ticket sellers—expressed concerns about these 

websites. In particular, they were concerned that consumers confused 

white-label websites for the venue’s website.

We reviewed 17 websites belonging to eight companies that were 

affiliates of the two secondary ticket exchanges offering white-label 

programs.51 We identified the sites by conducting online searches for nine 

venues (including stadiums, clubs, and theaters) on two of the largest 

search engines. All nine of the venues had at least one white-label site 

appear in the paid advertising above the search results. We observed the 

following:

• Sites could be confused with that of the official venue. Fourteen 

of the 17 white-label websites we reviewed used the venue’s name in

the search engine’s display URL, in a manner that could lead a 

consumer to believe it was the venue’s official website. In addition, 5 

of the 17 webpages used photographs of the venue and 11 provided 

 51Companies that use white-label ticketing sites typically have multiple websites displaying 

different URLs in online search results. We reviewed the purchase process for between 

one and four events per site. For each event, we recorded the prices and fees charged, 

and how and when the site disclosed its fees and that it was a resale site. 
Page 28 GAO-18-347 Event Ticket Sales

descriptions of the venue (such as its history) that could imply an 

association with the venue.

• Fees were higher than on other resale sites. Total ticketing fees 

(such as “service charges”) for the white-label sites ranged from 32 

percent to 46 percent of the ticket’s list price, with an average of 38 

percent. These fees were generally higher than those of other ticket 

resellers—for example, the secondary ticket exchanges that we 

reviewed charged average fees of 31 percent.

• Fees were revealed only near the end. All 17 of the white-label sites 

we reviewed disclosed their fees late in the purchase process. 

Ticketing fees and total prices were provided only after the consumer 

had entered either an e-mail address or credit card information.

• Other key disclosures were present but varied in their 

conspicuousness. All 17 of the white label webpages we reviewed 

disclosed on their landing page and check-out page that they were not 

associated with the venue and were resale sites whose prices may be 

above face value. However, this information was presented in a small 

font or in an inconspicuous location (not near the top of the page) for 

the landing page of 7 of these webpages, as well as for the check-out 

page of 12 of the 17 webpages.

• Ticket prices were higher than other resale sites. The ticket price 

charged for the events we reviewed on the white-label sites had an 

average markup of about 180 percent over the primary market price.52

By comparison, other ticket resale websites we reviewed had an 

average markup of 74 percent.

In some cases, we observed white-label websites selling event tickets 

when comparable tickets were still available from the primary seller at a

lower price. For example, two white-label sites were offering tickets to an 

event for $90 and $111, respectively, whereas the venue’s official 

ticketing website was offering comparable seats for $34. (All figures 

include applicable fees). Given the significantly higher cost for the same 

product, some consumers may be purchasing tickets from a white-label 

site only because they mistakenly believe it to be the official venue’s site. 

As we discuss in greater detail later in this report, in February 2018, 

Google implemented requirements for resellers using its AdWords service 

 52The primary market price includes the face value and any additional fees, which we 

obtained from the primary ticket sellers’ websites. We compared the primary market price 

to the total price on the white-label site (including fees).
Page 29 GAO-18-347 Event Ticket Sales

that are intended, among other things, to prevent consumer confusion 

related to white-label sites.

Ticket fees, the use of speculative tickets, ticket fraud, and designated 

resale exchanges have raised consumer protection concerns among 

government agencies, industry stakeholders, and consumer advocates.

Consumer protection advocates, event organizers, and some government 

entities have expressed concerns about high ticket fees.53 For example, 

the New York State Attorney General’s report expressed concern about

what it deemed high ticketing fees charged for unclear purposes. The 

report found that among online platforms, vendors of event tickets 

appeared to charge fees to consumers higher than most other online 

vendors.54 Concerns about high ticket fees also were frequently cited in 

2009 congressional hearings on the proposed merger of Live Nation and 

Ticketmaster.55 In addition, some managers and agents we interviewed 

said their clients were dissatisfied with high ticket fees. Data we received 

from FTC’s Consumer Sentinel Network indicated 67 complaints related 

specifically to event ticket fees from 2014 through 2016.56

A 2010 analysis by the Department of Justice said that the dominance of 

one company, Ticketmaster, in the primary ticketing market allowed the 

 53As previously noted, we found that the primary and secondary markets had average 

fees of 27 percent and 31 percent, respectively, of face value or listed price.

54New York State Office of the Attorney General, 31.

55Hearing on Competition in the Ticketing and Promotion Industry, Judiciary Committee of 

the United States House of Representatives, Subcommittee on Courts and Competition 

Policy, 111th Cong. 1 (Feb. 26, 2009) and The Ticketmaster/Live Nation Merger: What 

Does It Mean for Consumers and the Future of the Concert Business?, Committee on the 

Judiciary of the United States Senate, Subcommittee on Antitrust, Competition Policy and 

Consumer Rights of the Committee,111th Cong. 1 (Feb. 24, 2009). (For example, see 

testimony of Edmund Mierzwinski, Consumer Program Director, U.S. Public Interest 

Research Group.)

56FTC’s Consumer Sentinel Network is a database of consumer complaints received by 

FTC, as well as those filed with certain other federal and state agencies and 

nongovernmental organizations, including the Consumer Financial Protection Bureau and 

the Better Business Bureaus. For our review, we asked FTC staff to search the database 

from 2014 through 2016 using the terms “ticket,” types of events (e.g., concert, sport, 

theater, game, show), and “fee” or “charge.” We asked FTC to limit the search to 

complaints received against 6 primary ticketing companies and 11 secondary ticket resale 

exchanges or aggregators.

Other Consumer 

Protection Issues Have 

Been Identified

Amount Charged for Ticket 

Fees
Page 30 GAO-18-347 Event Ticket Sales

company to maintain high ticket fees.57 The report noted high barriers to 

entry for competitors, among which were high startup costs, 

Ticketmaster’s reputation for providing quality service to venues, and 

long-term exclusive contracts that large venues typically sign with one 

ticketing company. In addition, with the merger, Live Nation Entertainment 

owns both the largest primary ticket seller (Ticketmaster) and largest 

promoter (Live Nation), and owns many large venues and an artist 

management company. When the ticketing company is owned by a major 

promoter, the combined firm’s ability to bundle ticketing services and 

access to artists would require competitors to offer similar services in 

order to compete effectively, according to the Department of Justice 

analysis. In an attempt to mitigate these potential effects, the Department 

of Justice final judgment on the merger prohibited certain forms of 

retaliation against venues that contract with other ticketing companies. In 

the United Kingdom, where the venue and promoter typically contract with 

multiple ticket sellers, ticket fees are lower than in the United States—

around 10 percent to 15 percent of the ticket’s face value, according to a 

recent study.

58

Industry experts generally consider the secondary market for event 

ticketing to be more competitive than the primary market because of the 

large number of brokers participating in the industry.59 According to a 

report by the National Economic Council, fees in this market may be 

higher than expected because of the lack of transparency described 

earlier—consumers may be more willing to accept high fees and less 

likely to comparison shop when fees are disclosed at the end of a 

multistep purchase process. An FTC staff report made a similar point 

regarding hotel resort fees, noting that fees disclosed only at the end of 

the shopping process could harm consumers by making it more difficult to 

comparison shop for hotels.60 In addition, consumers who are led to 

 57Competitive Impact Statement, United States of America v. Ticketmaster Entertainment, 

Inc., No. 1:10-cv-00139 (D. D.C. Jan. 25, 2010).

58Michael Waterson, Independent Review of Consumer Protection Measures Concerning 

Online Secondary Ticketing Facilities, a report prepared at the request of the United 

Kingdom Department for Business, Innovation and Skills and Department for Culture, 

Media and Sport (London: May 2016), 30-31.

59For example, see Daniel A. Rascher and Andrew D. Schwarz, “The Antitrust 

Implications of ‘Paperless Ticketing’ on Secondary Markets,” Journal of Competition Law 

and Economics 9, no. 3 (May 2013), 659. 

60Sullivan, 27.
Page 31 GAO-18-347 Event Ticket Sales

believe that white-label ticketing sites are the official venue site may 

accept high fees because they think they are buying tickets from the 

primary ticketing provider, according to two industry representatives with 

whom we spoke.

The level of fees in the secondary market might also be affected by 

partnerships between the primary and secondary ticket seller. Primary 

ticketing companies sometimes offer resale options or use of designated 

resale exchanges (discussed below). The American Antitrust Institute has 

expressed the view that these relationships can reduce inventory for rival 

secondary sellers and in turn, can result in higher fees, as the primary 

ticket seller essentially has a monopoly over both markets.61

A speculative ticket refers to a ticket put up for sale by a broker when the 

broker does not yet have the ticket in hand, perhaps because the event 

has not yet gone on sale. Brokers may sell speculative tickets because 

they anticipate they will be able to secure the tickets (whether on the 

primary or secondary market) and sell them for a profit. The terms of use 

of most secondary sites we reviewed did not allow speculative ticket 

listings. However, while we were unable to identify comprehensive data 

on the extent of speculative tickets, numerous industry representatives 

told us that these sites commonly do not enforce this prohibition and 

listing of speculative tickets was widespread. One common form of 

speculative ticketing occurs when brokers offer tickets after a popular 

artist has announced a concert schedule but not yet begun ticket sales, 

according to industry representatives.

Several concerns exist around the use of speculative ticketing:

• The buyer may never get the ticket. Speculative ticket listings can 

result in canceled orders if the broker cannot obtain the ticket, or 

cannot obtain it at a price that would result in a profit. For example, it 

was reported that many fans who thought they purchased tickets to 

the 2015 Super Bowl actually purchased speculative tickets that were 

subsequently canceled when the supply of tickets was less than 

 61James D. Hurwitz, Restrictive Paperless Tickets: A White Paper by the American 

Antitrust Institute (Washington, D.C.: 2012), 36-37, 41-42. The American Antitrust Institute 

is an independent, nonprofit organization dedicated to promoting competition through its 

research, education, and advocacy. 

Speculative Tickets
Page 32 GAO-18-347 Event Ticket Sales

expected.62 According to industry stakeholders, consumers can 

typically obtain a refund on a canceled order from the broker or 

secondary ticket exchange, but may still face disappointment, 

inconvenience, or costs associated with nonrefundable travel to the 

planned event.

• The seat location is not guaranteed. Brokers selling speculative 

tickets typically do not specify the seat number but rather promise a 

certain section of the venue, according to two event organizers we 

interviewed. However, because the broker does not have the ticket in 

hand, consumers can receive seats that are worse or different than 

advertised.

• Speculative ticketing can cause consumer confusion. One large 

ticket resale exchange told us it only allows trusted brokers to sell 

speculative tickets under certain circumstances and requires sellers to 

use a special label for these listings. However, we observed other 

exchanges that are less transparent and do not make clear to the 

buyer that the ticket is speculative. Consumers may not be aware that 

tickets have not officially gone on sale yet and eventually may be 

available on the primary market at a lower price.

In its 2010 enforcement action against Ticketmaster and its resale 

exchange, TicketsNow.com, FTC alleged that the companies failed to tell 

buyers that many of the resale tickets advertised were being sold 

speculatively.63 The settlement required Ticketmaster and its affiliates to 

disclose if a ticket was being sold speculatively and to otherwise refrain 

from misrepresenting the status of tickets. FTC staff also sent warning 

letters to other resale companies that may have been at risk of violating 

the FTC Act with regard to their speculative ticketing practices. More 

recently, in 2015 a request by the New York State Attorney General 

resulted in three major ticket exchanges removing speculative ticket 

listings for an upcoming tour. Representatives from one of the secondary 

ticket exchanges told us that while it is difficult to determine if a listing is 

truly speculative, they have removed listings when they have information 

 62For example, see Geoff Baker, “Super Bowl dream becomes nightmare for Seahawks 

fans after shortage of tickets,” Seattle Times, January 31, 2015, accessed on February 8, 

2018. https://www.seattletimes.com/sports/seahawks/super-bowl-dream-becomesnightmare-for-seahawks-fans-after-shortage-of-tickets/.

63Complaint at 8-9, Federal Trade Commission v. Ticketmaster L.L.C., No. 1:10-cv-01093 

(D. Ill. Feb. 18, 2010).
Page 33 GAO-18-347 Event Ticket Sales

from event organizers to indicate that no one could have obtained the 

tickets.

Posing as a consumer, a GAO investigator made 11 inquiries to customer 

service representatives of two of the largest secondary ticket exchanges 

about two events listing tickets that appeared to be speculative.64 The 

customer service representatives generally acknowledged that the sellers 

did not yet have the tickets in hand but assured the investigator that the 

tickets would be provided.

Event tickets are sometimes fraudulent—for example, a fraudster may 

create and sell a counterfeit ticket or multiple copies of the same print-athome ticket, according to industry representatives. We did not identify 

comprehensive data on the extent of ticket fraud. Event organizers with 

whom we spoke said that they typically only see a handful of fraudulent 

tickets at popular events, and do not consider fraudulent ticketing to be a 

widespread problem. A limited search of FTC’s Consumer Sentinel 

Network data identified relatively few complaints—an estimated 19 

related to fraudulent tickets from 2014 through 2016.65 Industry 

representatives told us fraudulent tickets are most common for the most 

popular events and were often purchased on the street outside the venue 

or through an online classified advertisement.

According to industry representatives, fraudulent ticketing is rare on 

secondary market exchanges, in part because the exchanges can take 

action against sellers of fraudulent tickets, such as fining them or banning 

them from future sales. The National Association of Ticket Brokers 

requires its members to have a policy to reimburse consumers for

fraudulent tickets.66 Two secondary market participants told us the most 

 64We identified ticket listings that appeared to be speculative by searching for events that 

had been announced but for which tickets had not yet been released through a general 

on-sale or presale. Acting in an undercover capacity, the investigator contacted one 

company’s customer service through eight e-mail inquiries (each sent from a different email address) and the other company through three separate “live chats.” 

65Our estimate of the number of complaints from 2014 through 2016 related to ticket fraud 

was derived by having FTC staff search the Consumer Sentinel Network for complaints 

including the term “ticket” and at least one term signifying fraud (e.g., “fake,” “invalid”). 

The search included only complaints against six primary ticketing companies and 11

secondary ticket resale exchanges or aggregators that we identified.

66The National Association of Ticket Brokers is a trade association that represents ticket 

sellers in the secondary market and is comprised of over 200 broker members. 

Fraudulent Tickets
Page 34 GAO-18-347 Event Ticket Sales

common fraudulent activity they must address is credit card fraud by 

buyers rather than invalid tickets posted by sellers.

Designated resale exchanges are resale platforms that are linked to the 

primary ticket seller. They are most commonly used in major league 

sports. The four major sports leagues have agreements with one of two 

ticketing companies that allow consumers to buy and sell tickets through 

an official “fan-to-fan” resale marketplace. In addition, some individual 

teams and venues have an agreement with a third company to use its 

resale platform, which uses paperless tickets and can facilitate ticket 

transfers from one consumer to another or restrict transfers altogether 

(such as with nontransferable tickets).

On these exchanges, when a consumer lists a ticket for resale, the 

exchange electronically confirms the seller’s identity, then cancels the 

original ticket information (such as a barcode) and reissues the ticket with 

the new buyer’s name.

67 According to the three sports leagues we 

interviewed, designated resale exchanges are generally optional—for 

example, the sports leagues allow brokers and consumers to use other 

secondary market exchanges as well.

A representative of one of the major sports leagues told us the exchanges 

provide added revenue to teams because the teams receive some of the 

fee revenues from sales on the exchanges. The exchanges provide data 

on event attendees, which is valuable for marketing and security 

purposes, according to another sports league and a primary ticket seller. 

In addition, the exchanges can reduce resale fraud because the primary 

seller verifies the legitimacy of the ticket being resold, according to 

representatives of the three leagues we interviewed.

However, some academics and secondary market participants we 

interviewed have argued that designated resale exchanges work to the 

detriment of consumers. For example, one academic study stated that a 

primary ticket seller’s dominance in the secondary market can 

substantially reduce inventory for rival secondary sellers, thus impeding 

 67League officials we interviewed explained that although they have league-wide resale 

partnerships with certain companies, individual teams or clubs sometimes have their own 

partnerships with other companies. 

Designated Resale Exchanges
Page 35 GAO-18-347 Event Ticket Sales

competition in the resale market.68 The study stated that reduced 

secondary market competition, in turn, can result in higher fees.

In 2015, a U.S. district court dismissed StubHub’s antitrust complaint 

against the Golden State Warriors basketball team and Ticketmaster, 

LLC. StubHub claimed that the Warriors’ and Ticketmaster’s exclusive 

resale agreement restricted secondary market competition for 

professional basketball tickets in the Bay Area, but the court disagreed.69

Some designated resale exchanges use price floors, below which 

consumers may not sell their tickets. One sports league’s exchange has a 

price floor of $6, while the exchanges of two other sports leagues do not 

have league-wide price floors, according to league representatives. In 

addition, we identified instances of individual teams using price floors on 

their designated resale exchanges.70 One purpose of price floors is to 

protect brand reputation, according to league representatives, because 

too low a ticket price can lessen an event’s perceived value. Price floors 

also can prevent the secondary market from undercutting a team’s own 

(primary market) price. However, some consumer organizations and 

secondary ticket sellers said price floors were unfriendly to consumers. 

Season ticket holders might be unable to sell tickets for low-demand 

games for which market prices were lower than the floors. In addition, the 

New York State Attorney General’s office noted that consumers might not 

always be aware that price floors were in effect and thus pay more than 

they would on another exchange.71

 68Rascher and Schwarz, 693.

69Order Granting Defendants Motion to Dismiss, StubHub, Inc. v. Golden State Warriors, 

LLC, No. C 15-1436 MMC, 2015 U.S. Dist. LEXIS 151188, at *4 (N.D. Cal. Nov. 5, 2015). 

70For example, we identified one basketball team with a $20 price floor for tickets sold on 

its designated resale exchange, and a baseball team’s deal with a major ticket resale 

exchange that set a price floor of 50 percent of the ticket’s original season ticket price. 

71New York State Office of the Attorney General, 32. 
Page 36 GAO-18-347 Event Ticket Sales

Policymakers, consumer organizations, and industry participants have 

proposed or implemented a number of ticket resale restrictions and 

disclosure requirements, each of which have or would have advantages 

and disadvantages for consumers or industry participants (see table 5). 

Event ticketing is not federally regulated and some industry participants 

are using or exploring technology and other market-based approaches to 

address concerns related to secondary market activity.

Table 5: Potential Advantages and Disadvantages of Selected Legislative or Regulatory Actions Related to Ticket Resale

Action Description Key advantages Key disadvantages

Prohibiting 

nontransferable tickets

Prohibiting tickets that do 

not allow transfer from one 

person to another and 

therefore restrict resale

Ensures ticketholders can recoup 

costs on tickets they cannot use

Efficient allocation because tickets 

go to those willing to pay the most 

Reduced opportunity for consumers to 

access tickets at lower face-value price

Price caps Capping the price at which 

tickets can be resold (i.e., 

limits the markup)

Keeps prices down for consumers 

by restricting markups

Still preserves consumers’ ability 

to resell and recoup costs

Challenging to enforce

Could send resale activity 

underground, where there are fewer 

protections

Inefficient allocation because tickets do 

not go to those willing to pay the most

Requiring up-front 

disclosure of ticket fees or 

requiring all-in pricing

Legislative or regulatory 

requirement to provide upfront disclosure of fees 

during ticketing process or 

to wrap fees into the listed 

price

Increased transparency that 

allows better consumer decision 

making and facilitates comparison 

shopping

Would restrict companies’ flexibility in 

choosing how to disclose fees

Compliance challenges

Requiring disclosure of 

ticket’s face value on 

resale sites

Legislative or regulatory 

requirement that resellers 

show a ticket’s face value 

alongside the list price

Makes the markup transparent 

and helps ensure consumers 

know they are buying from a 

resale site

Can help consumers assess 

quality of seat

Could impose challenges for 

businesses in identifying face value

Challenging to enforce 

Requiring disclosure of 

ticket availability

Legislative or regulatory 

requirement that venue or 

event organizers disclose 

how many tickets are 

available when event goes 

on sale

Transparency for consumers on 

how many tickets are actually 

available for sale

Unclear how useful this information is 

for consumers

Compliance challenges

May require businesses to disclose 

proprietary information

Source: GAO | GAO-18-347

Note: None of these requirements are in effect at the federal level, but some have been implemented 

or considered at the state level, as described elsewhere in this report.

Effects of Ticket 

Resale Restrictions 

and Disclosures on 

Consumers and 

Business Would Vary
Page 37 GAO-18-347 Event Ticket Sales

Some event organizers make tickets to their events nontransferable—that 

is, the terms and conditions of the ticket prohibit its transfer from one 

person (in whose name the ticket is issued) to another. The prohibition 

can be enforced by requiring consumers to bring to the venue the credit 

or debit card used for purchase and matching photo identification. The 

consumer then receives a seat locator slip—akin to a consumer swiping a 

credit card at the airport to retrieve a boarding pass.

At least three states—Connecticut, New York, and Virginia—have laws 

that restrict ticket issuers’ ability to sell nontransferable tickets.72 Similar 

legislation has been introduced in several other states in recent years.73

The use of nontransferable tickets, even in states where they are legal, is 

relatively uncommon. For example, an artist advocacy group told us that 

some events that use them make only the first several rows of seats

nontransferable. One large primary ticketing company told us it estimated 

that less than 5 percent of its events used nontransferable tickets, while 

another told us nontransferable tickets represented less than 1 percent of 

its tickets in total. Almost all nontransferable tickets are for concerts; the 

practice is rare for sporting events and theater, according to industry 

stakeholders with whom we spoke.

Advantages to consumers of nontransferable tickets stem from the goal of 

preventing ticket resale—allowing consumers to pay face value rather 

than a higher price on the secondary market. As described earlier, 

markups on the secondary market can be substantial. Proponents of 

nontransferable tickets, which include a large primary ticket seller and 

some event organizers and well-known artists, have argued they are an 

important tool that makes it harder for brokers to resell tickets for profit.

We identified one empirical study on the effects of nontransferable tickets 

on resale activity. A 2013 study in the Journal of Competition Law and 

Economics compared two events using nontransferable tickets to 

comparable events using transferable tickets at the same venues. It found 

that nontransferable tickets significantly reduced resale and that prices 

 72See N.Y. ARTS & CULT. AFF. LAW § 25.30(1)(c) (Consol. 2018); 2017 CONN. ACTS 17-28

(Reg. Sess.); VA. CODE ANN. § 59.1-466.5 - 59.1-466.7 (2017). New York’s law has been 

in place since 2010, while Connecticut’s and Virginia’s laws were passed in 2017. 

73For example, legislation was introduced in Alabama, Maryland, and Missouri that would 

restrict nontransferable tickets.

Nontransferable Tickets 

Can Reduce the Price 

Some Consumers Pay but 

Also Limit Flexibility

Advantages of Nontransferable 

Tickets
Page 38 GAO-18-347 Event Ticket Sales

were significantly higher for the relatively small portion of nontransferable 

tickets that were resold.74

In addition, there is anecdotal evidence that nontransferable tickets 

reduce the rate of resale and allow more consumers to access tickets at 

face-value prices. Many stakeholders told us that making tickets 

nontransferable reduces secondary market activity, with some 

stakeholders citing specific examples.75 For instance, the manager of a 

large concert venue that primarily uses nontransferable tickets told us that 

resale is much less common for the venue’s events than for comparable 

events at similar venues. Similarly, the manager of a major musical artist 

told us that using nontransferable tickets for a subset of seats on a recent 

arena tour resulted in minimal listings for those seats on the secondary 

market. The New York State Attorney General’s report stated that 

nontransferable paperless tickets “appear to be one of the few measures 

to have any clear effect in reducing the excessive prices charged on the 

secondary markets and increasing the odds of fans buying tickets at face 

value.”76 But, while we identified evidence that nontransferable tickets 

limit resale, they may not eliminate resale because sellers may not follow 

the restriction.

However, other parties—including primary and secondary market 

participants, consumer advocacy groups, academics, and government 

agencies—have noted that nontransferable tickets can have the following 

disadvantages to consumers and adverse effects on markets:

Financial loss. With nontransferable tickets, ticket buyers who cannot 

attend an event can lose the ability to recoup their money through resale.

Inconvenience. Nontransferable tickets can be inconvenient because the 

buyer may need to present identification, a debit or credit card, or both, to 

 74Rascher and Schwarz, 655-708. In this study, a theoretical model was developed and 

an empirical analysis was performed to demonstrate the potential impact of “paperless 

ticketing,” a form of nontransferable tickets, on the quantity and price of resale tickets 

relative to conventional ticketing.

75Industry stakeholders expressing this view included two primary ticket sellers; two 

booking agents; two venue managers; Broadway representatives; an artists’ advocate 

group; a manager; a promoter; a secondary ticket seller; and the New York State Office of

the Attorney General. 

76New York State Office of the Attorney General, 36. The report recommended repealing 

the state’s prohibition on nontransferable tickets.

Disadvantages of 

Nontransferable Tickets
Page 39 GAO-18-347 Event Ticket Sales

gain entry to the venue, which can create delays. Nontransferable tickets 

also can create challenges for consumers buying tickets for others 

(including as a gift) because the ticket terms may require the buyer and 

original purchase card be present to gain entry. However, a primary ticket 

seller and a promoter told us these obstacles can be overcome—for 

example, through mechanisms allowing buyers to transfer tickets upon 

request, and by using processes to speed venue entry (such as 

automated kiosks).

Economic inefficiency. When nontransferable tickets are priced below 

the prevailing market price in the primary market, this creates excess 

demand, and tickets are sold without regard to consumers’ willingness to 

pay.77 Traditional economics maintains that an efficient market would 

result in tickets going to those willing to pay the highest price, which 

nontransferability inhibits by restricting a secondary market.78 In addition, 

some academics have noted that consumers may be less willing to buy 

nontransferable tickets because they do not offer the “insurance” that 

comes with the ability to resell them.79

Potential impingement on property rights. Some consumer groups 

and secondary market participants have argued that nontransferable 

ticket policies impinge on consumers’ property rights. These parties argue 

that once consumers buy a ticket, they should be able to do whatever 

they like with it.80

Effect on competition. The New York State Attorney General’s office 

and some economics literature have cautioned that use of 

 77Rascher and Schwarz, 682.

78Hurwitz, 43; Rascher and Schwarz, 667.

79See, for example, Pascal Courty, Pricing Challenges in the Live Events Industry: A Tale 

of Two Industries (January 2015), 7; Hurwitz, 38; and Rascher and Schwarz, 667. Staff we 

interviewed from the Department of Justice’s Antitrust Division also mentioned that the 

inability to resell nontransferable tickets could be a deterrent for potential buyers.

80Some courts have treated tickets as revocable licenses. For example, in a 2014 civil 

case regarding a National Football League (NFL) team’s ticket sales practices, the U.S. 

District Court of the Western District of Washington stated that tickets to an NFL game are 

not tangible goods, but instead revocable licenses. See e.g., Williams v. NFL, No. C14-

1089 MJP, 2014 U.S. Dist. LEXIS 155488, at *9 (D. Wash. Oct. 31, 2014); James T. 

Reese and Mark A. Dodds, “Let’s Hear It for the Home Team: Williams v. National 

Football League Upholds Geographic Ticket Sales Ban,” Sport Marketing Quarterly, vol. 

24, no. 2 (2015). 
Page 40 GAO-18-347 Event Ticket Sales

nontransferable tickets by primary ticketing companies can impede 

competition in the secondary market by making these companies’ own 

resale exchanges the only way to transfer tickets.81

Several states have caps on the price at which tickets can be resold, 

while others have repealed caps and some studies have questioned their 

enforceability. For example, Kentucky generally prohibits the resale of 

event tickets for more than either face value or the amount charged by 

the venue, and Massachusetts prohibits resale by brokers of most tickets 

for more than $2 above face value, with the exception of relevant service 

charges.82 New Jersey allows a maximum markup of 20 percent or $3 

(whichever is greater) for nonbrokers and a maximum markup of 50 

percent for registered brokers, but does not limit resale prices for 

nonbrokers for sales over the Internet.83 A number of other states—

including Minnesota, Missouri, New York, and Connecticut—repealed 

their price cap laws in the 2000s. However, the New York State Attorney 

General’s 2016 report recommended bringing back a price cap, through a 

“reasonable limit” on resale markups.84

Price caps are generally intended to protect consumers from high 

markups and increase the fairness of ticket distribution so that the 

wealthiest consumers do not have disproportionate access to tickets. In 

theory, price caps offer consumers the advantages of nontransferable 

tickets without the disadvantages: they limit high secondary-market prices 

but still allow consumers to transfer tickets to others or resell tickets they 

cannot use.

However, three government studies we reviewed stated that price caps 

are difficult to enforce and are rarely complied with. A 1999 report by the 

New York Attorney General noted that ticket resellers “almost universally 

disregarded” a cap in place at the time.85 Representatives from the office 

 81New York State Office of the Attorney General, 37; Hurwitz, 36-37; Rascher and 

Schwarz, 693-694. 

82See KY. REV. STAT. ANN. § 518.070 (LexisNexis 2017); MASS. GEN. LAWS ch. 140, 

§ 185D (2017).

83N.J. STAT. § 56:8-33 (2017).

84New York State Office of the Attorney General, 37.

85New York State Office of the Attorney General, Why Can’t I Get Tickets?: Report on 

Ticket Distribution Practices May 1999, 21. New York repealed its price cap in 2007.

Caps on Resale Prices 

Can Have Advantages and 

Disadvantages
Page 41 GAO-18-347 Event Ticket Sales

told us enforcement of such a cap might be easier now because the 

secondary market is largely on the Internet, which offers greater price 

transparency. A 2016 study of the United Kingdom’s ticket market noted 

that enforcement of a price cap was complicated by the fact that ticket 

resellers were not a well-defined group and sales could occur on various 

platforms and across jurisdictions.86 Similarly, the New York State 

Department of State noted in 2010 that enforcement of price caps can be 

challenging.87

In addition, critics of price caps have said that caps might force resale 

activity underground, which would reduce transparency and protections 

(such as refund guarantees) that legitimate secondary market exchanges 

provide. Both the largest ticket exchange and the largest primary market 

ticket company have opposed price caps, with the ticket exchange 

arguing that they would result in street-corner transactions, where the risk 

of counterfeit and fraud would be significant.88 On formal exchanges, 

transactions can be monitored and regulated. As with nontransferable 

tickets, price caps also can create economic inefficiencies because 

tickets are not necessarily allocated to those willing to pay the highest 

price.89

A 2010 study by the New York State Department of State compared 

publicly available secondary market listings for high-demand concerts in 

New York to the same artists’ concerts in nearby states with price caps. It 

found no definitive evidence that price caps resulted in greater or lesser 

availability on the secondary market or in lower resale prices.90 The study 

noted that online resale prices routinely exceeded the price caps. 

However, the authors of the study acknowledged that their findings were 

 86Michael Waterson, Independent Review of Consumer Protection Measures Concerning 

Online Secondary Ticketing Facilities, a report prepared at the request of the United 

Kingdom Department for Business, Innovation and Skills and Department for Culture, 

Media and Sport (London: May 2016), 22-23, 150-151. 

87New York State Department of State, Report on Ticket Reselling and Article 25 of the 

Arts and Cultural Affairs Law (Albany, N.Y.: Feb. 1, 2010), 33. 

88StubHub, “StubHub Open Letter to Fans Following Passage of the Ontario Ticket Sales 

Act,” December 13, 2017, accessed December 14, 2017, 

https://www.newswire.ca/news-releases/stubhub-open-letter-to-fans-following-passage-ofthe-ontario-ticket-sales-act-663928593.html. 

89See, for example, Hurwitz, 35. 

90New York State Department of State, 26.
Page 42 GAO-18-347 Event Ticket Sales

limited by their inability to obtain data on ticket sales and availability from 

secondary sellers.

Legislative or regulatory actions to improve disclosure and transparency 

of ticket fees, resale markups, and ticket availability have advantages and 

disadvantages.

Some government stakeholders have suggested improving fee 

transparency through a legal requirement to disclose ticket fees earlier in 

the purchase process. As discussed earlier, ticketing companies in the 

primary and secondary markets vary on when and how they disclose their 

fees, and some disclose fees only upon checkout. No federal law 

expressly addresses fee disclosure in event ticketing. However, at least 

one state requires disclosure of fees at the beginning of the purchase 

process.91

On the primary market, up-front fee disclosure helps decision making by 

informing consumers of the total ticket price early in the process. It also 

helps consumers decide whether to buy from the ticketer’s website or at 

the box office, where there typically are no fees. On the secondary 

market, up-front fee disclosure aids comparison shopping by helping 

consumers identify the resale exchange with the best total price. Sellers 

that do not provide enough or full information on prices through hidden 

fees could have competitive advantage because they would be perceived 

as offering lower prices over their competitors who do provide full 

information showing the price. For products and services in general, FTC 

staff guidance advocates that fees be disclosed up front, particularly 

before the point at which the consumer has decided to make a 

purchase.92

 91Connecticut requires any advertisement for an in-state event to include the total price 

and the portion of that price (in dollars) that represents a service charge. CONN. GEN. STAT.

§ 53-289a (2017).

92For example, see Federal Trade Commission, .com Disclosures: How to Make Effective 

Disclosures in Digital Advertising, March 2013, 14. Similarly, Canada’s Competition 

Bureau, an independent Canadian law enforcement agency, has stated that not disclosing 

fees up front can be misleading to consumers because the advertised price is not 

attainable. See Competition Bureau Canada, “Calling All Ticket Vendors: Be Upfront about 

the True Cost of Tickets,” July 4, 2017, accessed March 12, 2018, 

https://www.canada.ca/en/competitionbureau/news/2017/06/calling_all_ticketvendorsbeupfrontaboutthetruecostoftickets.html.

Stakeholder Views Vary on 

Effects of Additional 

Disclosure Requirements

Up-front Fee Disclosure
Page 43 GAO-18-347 Event Ticket Sales

Figure 2 provides examples of different approaches to displaying prices 

and fees.

Figure 2: Hypothetical Examples of How a Ticket Price and Fees Can Initially Be 

Displayed

Note: These examples are illustrative and are not based on actual tickets or events.

Currently, FTC relies on the Federal Trade Commission Act—which 

prohibits unfair or deceptive acts or practices—to address problems 

related to fee disclosures. But FTC staff said it is challenging and 

resource-intensive to use the act to address inadequate fee disclosures 

industry-wide because it requires proving violations on a case-by-case 

basis.93 FTC staff told us that, depending on the circumstances, a 

legislative disclosure requirement that specified requirements for fees 

could facilitate enforcement activity and create a more level playing field 

 93Industry stakeholders expressing this view included two managers, one agent, one 

promoter, two artist advocacy groups, four secondary market ticket exchanges, and the 

National Association of Ticket Brokers.
Page 44 GAO-18-347 Event Ticket Sales

for consumers and sellers. Eleven industry stakeholders and three 

consumer advocacy groups with whom we spoke similarly expressed 

support for a requirement that ticketing fees be disclosed up front. Many 

noted that fees should be fully transparent to consumers.

However, a primary ticket seller, two venue managers, and a secondary 

ticket seller we interviewed questioned the need for an up-front fee 

disclosure requirement. For example, a primary ticket seller stated that 

knowing fees up front would not affect a consumer’s decision of whether 

or not to buy a ticket. The two venue managers believed that the timing of 

the fee disclosure was not important, as long as fees are disclosed before 

consumers complete the purchase. Representatives of one secondary 

ticket exchange said that up-front disclosure of fees could be challenging 

because a ticket’s fee is not stable—for example, the fee can change 

based on price fluctuations, different delivery methods, and the use of 

promotion codes.

The National Economic Council has stated that “all-in pricing,” a form of 

up-front pricing, may be preferable to other methods of fee disclosure.94

All-in pricing incorporates the ticket’s face value and all mandatory fees 

and taxes, as illustrated in figure 2 above. According to the National 

Economic Council, all-in pricing eases comparison across vendors. The 

FTC staff report analyzing hotel resort fees supported all-in pricing for that 

industry because it said that breaking out fees, instead of providing a 

single total price, hindered consumer decision making and often resulted 

in consumers underestimating the total price.95 Officials from two state 

attorney general offices told us that all-in pricing could be advantageous, 

noting that fee disclosures represent their most significant enforcement 

issue related to the ticketing industry.

Three secondary ticket sellers told us they might support a requirement to 

provide all-in pricing, but only if it was required of all ticket sellers. In 

2014, the largest secondary market ticketing company began using all-in 

pricing, with its listings displaying a single total price that incorporated 

fees. However, the company soon discontinued all-in pricing as the 

default because, it told us, it put the company at a competitive 

disadvantage with other secondary market providers whose fees were not 

 94White House National Economic Council, 16. 

95Sullivan, 27.
Page 45 GAO-18-347 Event Ticket Sales

included in the initial ticket price displayed to consumers.96 A requirement 

that all ticket sellers provide up-front fee disclosure would mitigate or 

resolve that issue.

One argument against a requirement for all-in pricing is that such 

regulation would restrict ticket companies’ flexibility in choosing how to 

disclose fees. In addition, a manager, a promoter, and two artist advocacy 

groups said all-in pricing could give fans the incorrect impression that the 

artist was charging the full ticket price and receiving its revenues, 

because the portion of the price going toward ticketing fees would not be 

transparent.

Some federal and state policymakers have proposed requirements for 

resellers to disclose a ticket’s face value on secondary ticket websites. 

Georgia and New York State have enacted similar requirements, with 

statutes requiring resellers to disclose both the face value of tickets and 

their list price.97

Requiring that ticket resellers disclose the ticket’s face value can have 

several advantages. First, it makes the reseller’s markup transparent. 

Second, it can help consumers assess the quality of the seat location and 

compare similar seats across resale listings. Third, it might reduce the 

possibility that consumers mistake a reseller’s website for a venue 

website, as described earlier. This, in turn, could encourage consumers to 

recognize they are viewing a secondary market exchange and 

comparison shop for a better price elsewhere.

However, a requirement that resellers disclose a ticket’s face value can 

present challenges because the definition of “face value” may not always 

be clear, according to three ticket resellers and FTC Bureau of Consumer 

Protection staff. If the face value does not incorporate fees and taxes 

charged on the primary market, it would not reflect the full amount paid by 

 96The company still provides the customer the option of displaying all-in pricing at the 

listing page, as do some other secondary market providers.

97Georgia’s ticketing law requires brokers to disclose to the purchaser, in writing, the 

difference between a ticket's face value and the price being charged. GA. CODE ANN. § 43-

4B-28(a)(3) (2017). New York requires licensed resellers to post a price list showing the 

established (face value) price charged by the operator of the place of entertainment for 

which the ticket is being resold. N.Y. ARTS & CULT. AFF. LAW §25.23 (Consol. 2018). At 

least two foreign jurisdictions—the United Kingdom and Ontario, Canada—have similar 

laws, according to a United Kingdom government study of the country’s ticket resale 

market and a Canadian government press release.

Disclosing Face Value on 

Resale Sites
Page 46 GAO-18-347 Event Ticket Sales

the original buyer. Similarly, some tickets are sold through VIP packages 

that do not itemize the price of the ticket and other components, such as 

backstage access or parking. In addition, with dynamic pricing, a ticket’s 

face value can change frequently. Furthermore, season tickets may 

display a higher face value than the season ticket holder paid because 

teams usually sell the packages at a discount.

A requirement to disclose a ticket’s face value also could create 

compliance costs for secondary ticket exchanges, and could be difficult to 

enforce, according to some stakeholders. Three secondary ticket 

exchanges told us they do not currently collect information on a ticket’s 

face value and would have difficulty verifying the value provided by the 

listing broker—in part because of the challenges in defining face value, as 

described above. The New York State Office of the Attorney General 

stated in its 2016 report that most resellers cannot comply with the state’s 

disclosure requirement because most secondary ticket exchanges do not 

offer the option to show the ticket’s face value alongside its list price, 

despite having the capability to add such functionality.98 In addition, an 

official from Georgia’s Athletic and Entertainment Commission told us that 

resellers largely disregarded the state’s requirement to disclose face 

value.

Another proposal, advocated by secondary market stakeholders, among 

others, would require primary ticket sellers to disclose how many tickets 

are available when an event first goes on sale to the general public. For 

instance, a venue or ticket seller might be required to provide the venue 

capacity and number of tickets available for sale after accounting for 

presales and holds. A 2017 law in Ontario, Canada, requires primary 

ticket sellers to provide certain information about venue capacity and 

presales, according to testimony by the Ontario Attorney General.99

Such a disclosure would provide consumers a clearer picture of ticket 

availability and help them manage expectations and make informed 

decisions, according to three consumer advocacy groups and two 

academics with whom we spoke. In addition, the National Association of 

Ticket Brokers and a secondary ticket exchange stated that disclosing 

ticket availability would shed light on what some consider excessive holds 

 98New York State Office of the Attorney General, 34.

99Official Report of Debates (Hansard) No. 136, Legislative Assembly of Ontario, 2nd 

Session, 41st Parliament (Dec. 13, 2017).

Disclosing Ticket Availability
Page 47 GAO-18-347 Event Ticket Sales

and presales by the primary market. They said that brokers often are 

blamed when events quickly sell out on the primary market, whereas 

there may have been relatively few tickets available for sale in the first 

place. The New York State Office of the Attorney General stated that the 

lack of transparency about the manner in which tickets are distributed 

creates a level of mistrust among consumers.

However, many primary market stakeholders with whom we spoke—

including promoters, managers, venue operators, and primary ticket 

sellers—said such a disclosure would have little-to-no benefit. First, some 

of them noted that ticket inventory can change as event production details 

evolve and holds are released, making it difficult to provide an accurate 

number of tickets available at any one time. Second, some said this 

disclosure would be confusing or meaningless for consumers, with one 

promoter noting that for high-demand events, a consumer’s odds of 

getting a ticket are low regardless of whether he or she knows the 

number of available tickets. Another promoter noted that the seat maps 

used to select seats when purchasing tickets already provide information 

on ticket availability. Many stakeholders also told us such a disclosure 

would only help brokers by giving them information useful in buying 

tickets and setting resale prices. In addition, a venue manager noted that 

information on ticket sales is considered proprietary and artists and event 

organizers should not be required to disclose confidential business 

information.100

Federal agencies face constraints in addressing ticketing issues. Some 

industry players are implementing technological and market-based 

approaches that seek to address concerns about secondary market 

activity.

 100When initially introduced in October 2017, the Ticket Sales Act enacted by Ontario, 

Canada, included a provision requiring advance disclosure of the number of tickets to be 

sold to the general public, according to a statement by the Attorney General of Ontario. He 

stated that this provision was dropped after opposition from artists and venue operators, 

who claimed, among other things, that it would provide useful market information 

advantageous to ticket brokers. 

Event Ticketing Is Not 

Federally Regulated and 

Some Stakeholders Cite 

Market-Based Approaches 

to Address Concerns 

about Secondary Market 

Activity
Page 48 GAO-18-347 Event Ticket Sales

As noted earlier, the event ticketing industry is not federally regulated. In 

contrast, in the airline industry, the Department of Transportation can 

issue regulations regarding the disclosure of airline fees.101 Staff from 

FTC’s Bureau of Consumer Protection told us that—in addition to the 

enforcement activity noted earlier—they monitor consumer complaints 

related to the event ticket industry. However, they said they have 

resource and other constraints that make it difficult to conduct industrywide investigations related to ticketing practices.

Issues around the level and transparency of fees are not unique to the 

event ticketing industry. For example, as noted earlier, FTC staff have 

raised concerns about mandatory “resort fees” charged by many hotels 

but not immediately disclosed (such as in online price search results).102

In addition, according to the National Economic Council, sellers of other 

goods and services—such as car dealers and telecommunications 

companies—sometimes offer low prices up front that rise substantially 

with the addition of mandatory fees revealed later in the purchase 

process.103 As such, options for regulating the transparency of fees can 

have applicability broader than that of event ticketing.

As noted earlier, the BOTS Act, which prohibits circumventing security 

measures or other systems intended to enforce ticket purchasing limits or 

order rules, went into effect in December 2016. However, a variety of 

industry, consumer, academic, and government stakeholders have 

expressed doubt that the BOTS Act would have much of an effect on 

prohibited bot use. Several of these stakeholders told us that bot users 

can easily evade detection and that enforcement of the act would be 

extremely difficult, in part because a lot of bot use occurs—or could 

shift—outside the United States. As of February 2018, FTC had not taken 

any enforcement action related to the act, but FTC staff told us they were 

monitoring the situation.

 101For example, since 2010, the Department of Transportation has taken or has proposed 

a range of actions to improve the transparency of airlines’ fees for optional services, such 

as requiring certain airlines to disclose optional service fees on their websites. See GAO, 

Commercial Aviation: Information on Airline Fees for Optional Services, GAO-17-756 

(Washington, D.C. Sept. 20, 2017).

102Sullivan, 1.

103White House National Economic Council, 9-15. 

Federal Regulatory 

Environment
Page 49 GAO-18-347 Event Ticket Sales

The degree to which legislation combatting bots is effective may depend 

in part on the extent to which state attorneys general pursue enforcement 

actions. As of February 2018, we identified two states that had taken 

enforcement actions related to bot use. In May 2017, the New York State 

Office of the Attorney General announced settlements totaling $4.11 

million with five ticket brokers which, among other offenses, violated New 

York State law by using bots to purchase and resell tickets.104 In April 

2016, the office announced settlements totaling $2.7 million with six ticket 

brokers for similar violations.105 In February 2018, the Washington State 

Office of the Attorney General announced settlements totaling $60,000 

with two ticket companies that used bots in violation of the state’s 

ticketing law.106

Industry players, including ticket companies and event organizers, are 

using or exploring technology and market-based approaches that seek to 

address concerns about secondary market activity. Examples of these 

approaches and their potential effects include the following:

• Delivery delays. Ticket sellers sometimes use delivery delays, 

meaning they do not provide the ticket immediately upon purchase. 

Instead, buyers receive their tickets (in paper or print-at-home form) 

closer to the day of the event. Delivery delays can inhibit resale 

activity because they give brokers less time to buy and resell tickets, 

and allow primary ticket sellers to review whether brokers and bots 

made bulk purchases, according to some promoters and primary 

ticket sellers. However, secondary market sellers we interviewed 

generally argued against delivery delays, with two sellers saying it can 

 104New York State Office of the Attorney General, A.G. Schneiderman Announces $4.19 

Million In Settlements with Six Companies That Illegally Purchased and Resold Hundreds 

of Thousands of Tickets to Concerts and Other NY Events (May 11, 2017). 

105New York State Office of the Attorney General, A.G. Schneiderman Announces $2.7 

Million In Settlements With Six Ticket Brokers That Illegally Bought And Resold Tickets In 

Bulk (Apr. 27, 2016).

106Washington State Office of the Attorney General, Ticket Sales Company to Pay $60k 

for Use of Ticket Bots (Feb. 8, 2018).

Market-Based Approaches
Page 50 GAO-18-347 Event Ticket Sales

be inconvenient and stressful for consumers to receive a ticket just a 

few days before an event.107

• Dynamic pricing. The use of dynamic pricing—which adjusts prices 

over time based on demand—can reduce secondary market activity 

by pricing tickets closer to their market clearing price. Raising primary 

market ticket prices, such as through dynamic pricing, does not 

necessarily benefit consumers but can help ensure that more ticket 

revenue accrues to the artist or team rather than ticket resellers.

• Verified fan program. At least one major ticket company has a 

program to sell tickets to pre-approved “verified fans,” to help ensure 

that more consumers and fewer brokers can access tickets on the 

primary market.

• New technology. Two stakeholders noted the potential for distributed 

ledger technology in ticketing.108 The technology associates a unique 

identification code with the ticket and its owner, which can help restrict 

transfer of the ticket and ensure its authenticity.

• Adding concerts. Artists can seek to make their ticket prices 

accessible by increasing the supply of seats—for example, one major 

artist has added concert dates with the express purpose of matching 

ticket supply to demand to prevent higher resale prices.

• Face-value resale exchanges. Resale exchanges used by some 

artists only allow resale at face value (plus a limited amount to 

account for primary market fees). This allows consumers to recoup 

their ticket costs if their plans change, while preventing resale 

markups.

Market-based approaches also may augment regulatory and enforcement 

action with regard to problems discussed earlier around transparency. In 

February 2018, Google’s AdWords service—which offers paid advertising 

alongside search results—implemented new certification requirements for 

businesses that resell event tickets. First, resellers using AdWords must 

clearly disclose on their website or mobile application that they are a 

secondary market company and not the primary provider of the tickets. 

 107In addition, the National Association of Ticket Brokers and one ticket reseller told us 

they view delivery delays as an attempt to force ticketholders to use the primary sellers’ 

own secondary marketplaces. They said this was demonstrated by tickets that otherwise 

have delivery delays being available for instant resale on the resale sites of some primary 

sellers.

108Distributed ledger technology allows participants in a peer-to-peer network to share and 

retain identical secured records through a decentralized database.
Page 51 GAO-18-347 Event Ticket Sales

They cannot imply they are the primary provider by using words such as 

“official” or by including the artist or venue name in their website’s URL—

practices we noted earlier that were being used by some white-label 

websites. Second, resellers must prominently disclose when their ticket 

prices are higher than face value and disclose a price breakdown, 

including any fees, before the customer provides payment information. 

Google said in a statement that these measures were intended to protect 

customers from scams and prevent potential confusion. However, due to 

the recency of this change, it is too early to determine how it will affect the 

marketplace.

In addition, the advertising industry’s self-regulatory organization has 

taken steps to address potentially misleading pricing practices in the 

ticket industry. The Advertising Self-Regulatory Council sets standards for 

truth and accuracy for national advertisers, monitors the marketplace, and 

holds advertisers responsible for their claims.109 As noted earlier, the 

organization recently referred a major ticket company to FTC for not 

following its recommendations to conspicuously disclose its fees.110

Although the council can play a role in monitoring deceptive advertising 

related to ticketing, it also faces constraints—for example, it addresses 

practices case-by-case and its recommendations depend on voluntary 

compliance by the advertiser.

No matter what efforts are made to address concerns about the ticket 

marketplace, some of the consumer dissatisfaction with event ticketing 

stems from an intractable issue: demand for tickets to highly popular 

events exceeds supply. As such, no activity, outside of expanding the 

supply, is likely to effectively address one key source of consumer 

dissatisfaction: that tickets are not available to popular sold-out events.

We provided a draft of this report to DOJ and FTC for review and 

comment. We received technical comments from FTC, which we

incorporated as appropriate. We also provided relevant excerpts of the 

draft for technical review to selected private parties cited in our report, 

and included their technical comments as appropriate.

 109Advertising Self-Regulatory Council, “ASRC Snapshot,” accessed February 2, 2018, 

http://www.asrcreviews.org/about-us/. 

110Advertising Self-Regulatory Council, “NAD Refers StubHub Pricing Claims to FTC for 

Further Review After Advertiser Declines to Comply with NAD Decision on Disclosures,” 

(New York, NY: Jan. 16, 2018). 

Agency Comments 
Page 52 GAO-18-347 Event Ticket Sales

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to DOJ, FTC, the 

appropriate congressional committees and members, and others. In 

addition, the report will be available at no charge on the GAO website at 

http://www.gao.gov.

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-8678 or clementsm@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix II.

Michael Clements

Director, Financial Markets and Community Investment
Appendix I: Objectives, Scope, and 

Methodology

Page 53 GAO-18-347 Event Ticket Sales

The objectives of this report were to examine (1) what is known about 

primary and secondary online ticket sales, (2) the consumer protection 

concerns that exist related to online ticket sales, and (3) potential 

advantages and disadvantages of selected approaches to address these 

concerns. The scope of our work generally focused on ticketing for large 

concert, theater, and sporting events for which there is a resale market.

To develop background information on the U.S. ticketing industry, we 

analyzed business classification codes from the North American Industry 

Classification System, which assigns a 6-digit code to each industry 

based on its primary activity that generates the most revenue. The code 

we selected, “All Other Travel Arrangement and Reservation Services,”

includes theatrical and sports ticket agencies, as well as automobile club

road and travel services and ticket offices for airline, bus, and cruise ship 

travel. Because the Census data do not distinguish event ticketing from 

other services in particular, we determined the data do not provide a 

reliable count of companies in the event ticketing industry. In addition, we 

obtained publicly available data from private research firms and reviewed 

the largest publicly held ticketing companies’ annual public filings with the 

Securities and Exchange Commission (Form 10-K). We also collected 

information from firms that collect data related to the ticketing industry, 

such as IBISWorld and LiveAnalytics.

To examine what is known about primary and secondary online ticket 

sales, we reviewed data related to ticket prices and sales published by 

Pollstar, a concert industry trade publication, and the Broadway League, 

a trade organization representing commercial theater. In addition, we 

obtained and analyzed data on ticket volume and resale prices for a 

nongeneralizable sample of 22 events. These events were selected 

because they (1) occurred in relatively large venues (more than 500 

seats) that typically experience ticket resale activity; (2) represented a mix 

of event types (13 concerts, 3 commercial theater productions, and 6

sporting events); and (3) represented a mix of popularity, including 17 

events that would be expected to be in high demand. We defined highdemand events as those that were likely to sell out, which we assessed 

by reviewing past attendance at other events for the same artist or 

theatrical event. For sports, we assessed demand by reviewing team 

performance and rankings. We collected data from October 16 through 

December 20, 2017. For each event, we analyzed:

• resale prices and volume, through data obtained from publicly 

available listings on the websites of two secondary ticket exchanges;

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 54 GAO-18-347 Event Ticket Sales

• primary market prices and availability, through data obtained from 

the websites of primary market ticket sellers; and

• event capacity, through data obtained from Billboard or Pollstar 

(trade publications) for concerts, the Broadway League for theater, 

and ESPN.com (a media company) for sporting events.

To examine consumer protection concerns, we reviewed the websites of 

6 primary market ticket sellers, 11 secondary ticket exchanges, and 8 

“white-label” ticket websites.1 We collected data from June 19, 2017, 

through January 16, 2018.

• For the primary market ticket seller that represents the majority of 

market share, we observed the online ticket purchase process for 23 

events. Three events were selected using the process described 

below and the remaining 20 were chosen to reflect 2 events at each of 

10 venues, selected because they were among the 200 top-selling 

arenas or 200 top-selling theaters in the United States in 2017, 

according to Pollstar.

• For each of the 5 other primary market ticket sellers and the 11 

secondary ticket exchanges, we observed the online ticket purchase 

process for 1–5 events. For each primary ticket seller, we selected 

one event per category (concert, theater, and sports). For consistency 

and comparability across companies, we also limited events to the 

same state (which did not extensively limit ticket resale) and time 

period. We also selected 2 events in another state because they used 

nontransferable tickets. For the secondary ticket exchanges, we used 

3–5 events from our review of primary ticket sellers’ websites. If the 

event was no longer available, we selected an alternative event at the 

same venue.

• For each of the 8 white-label ticket sellers, we reviewed 1–4 events 

from the events described above. In some cases, the same event was 

not available so we selected an alternative event at the same venue.

For these events—31 events in total—we documented (1) the ticket fees 

charged, (2) at what point in the purchase process the fees were 

disclosed, and (3) any restrictions to the ticket. In addition, we assessed 

 1

A white-label website is a sales website built by one company that allows affiliates to use 

the software to build their own, uniquely branded websites, which often appear as paid 

results of Internet searches for venues and events. We identified these websites by 

conducting searches on two of the largest search engines for the venues of the events we 

selected for review. 
Appendix I: Objectives, Scope, and 

Methodology

Page 55 GAO-18-347 Event Ticket Sales

the clarity, placement, and font size of the fees, restriction information, 

and—for white-label websites—disclaimers that the website was a ticket 

resale website. We worked with a GAO investigator to review the 

websites that required users to provide an e-mail address or credit card 

information before viewing fees. Analysts followed a protocol to help 

ensure consistency of observations and completed a data collection 

instrument for each website. A second analyst independently reviewed 

each website to verify the accuracy of information collected by the first 

analyst. Any discrepancies between the two analysts were identified, 

discussed, and resolved by referring to the source websites.

A GAO investigator acting in an undercover capacity contacted the 

customer service departments of three large secondary ticket exchanges 

to inquire about two events for which tickets were nontransferable (not 

allowed to be resold) and two events for which listed tickets were 

speculative (not yet in-hand by the seller). The nontransferable tickets 

were identified through press releases and articles about popular touring 

artists and the speculative tickets were identified by searching for events 

that had been announced but were not yet for sale on the primary market. 

The investigator contacted customer service through 16 e-mails to one 

company and 8 online “live chats” with another company. For the third 

company, the investigator sent 8 e-mails about nontransferable tickets 

and did not inquire about speculative tickets because this company 

labeled such tickets. We also contacted the venues hosting these events 

to help assess the accuracy of the information provided by the ticket 

companies’ customer service departments.

In addition, we reviewed enforcement activity by federal and state 

agencies related to ticketing and ticket companies. We also collected 

information on the number of consumer complaints by requesting the 

Federal Trade Commission (FTC) conduct a search of its Consumer 

Sentinel Network database, which includes complaints submitted to FTC, 

the Consumer Financial Protection Bureau, the Better Business Bureaus, 

and other sources. The search results covered calendar years 2014–

2016 and used the term “ticket” with terms related to events (e.g., 

“concert,” “sport,” “theater”), sold-out events (e.g., “sold-out”); fees; 

fraudulent tickets (e.g., “fake”); delayed delivery (e.g., “late,”); or 

nontransferable tickets (e.g. “paperless”). We selected our initial search 

terms by reviewing terms used in similar complaints on the Better 

Business Bureau website. We made modifications to our search string 

based on suggestions from FTC staff who reviewed the results of a 

preliminary search. To help ensure that results were related to event 

ticket sellers, we limited the search to complaints against the 6 primary 
Appendix I: Objectives, Scope, and 

Methodology

Page 56 GAO-18-347 Event Ticket Sales

ticket sellers and 11 secondary ticket exchanges in our scope. We 

assessed the reliability of the complaint data by interviewing agency 

officials. In addition, we have assessed the reliability of Consumer 

Sentinel Network data as part of previous studies related to consumer 

protection and found the data to be reliable for the purposes of gauging 

the extent of consumer complaints about event ticketing. However, in 

general, consumer complaint data have limitations as an indicator of the 

extent of problems. For example, not all consumers who experience 

problems may file a complaint, and not all complaints are necessarily 

legitimate or categorized appropriately. In addition, a consumer could 

submit a complaint more than once, or to more than one entity, potentially 

resulting in duplicate complaints.

To examine the potential advantages and disadvantages of selected 

approaches to address consumer protection concerns, we reviewed 

federal and selected state laws related to event ticket sales. At the federal 

level, these included the Better Online Ticket Sales Act of 2016 and 

relevant provisions of the Federal Trade Commission Act. To determine 

which states had laws related to ticket resale or disclosure, we reviewed 

compilations of state ticketing laws from the National Association of Ticket 

Brokers, a secondary ticket seller’s website, and a law firm publication, 

and we conducted independent research and verification. We reviewed 

ticketing-related legislation—selected for its relevance to the approaches 

covered in our review—in Connecticut, New York, and Georgia. We 

reviewed state government reports and interviewed state officials to get 

information on the states’ experiences with these laws. We also consulted 

foreign government reports to obtain information on relevant laws or 

regulations in Canada and the United Kingdom, which have reported 

similar consumer protection issues as we reviewed in our report.

To address all of our objectives, we conducted searches of various 

databases, such as ProQuest, Academic OneFile, Nexis, Scopus, and the 

National Bureau of Economic Research, to identify sources such as peerreviewed academic studies; law review articles; news and trade journal 

articles; government reports; and hearings and transcripts related to 

ticketing issues. We examined summary-level information about each 

piece of literature, and from this review, identified articles that were 

germane to our report. We generally focused on articles from 2009 and 

later. We identified additional articles and reports through citations in 

literature we reviewed and from expert recommendations.

For the articles we used to cite empirical findings or to support arguments 

on advantages and disadvantages of selected resale restrictions or 
Appendix I: Objectives, Scope, and 

Methodology

Page 57 GAO-18-347 Event Ticket Sales

disclosure requirements, we conducted a methodology and soundness 

review. We eliminated one study on pricing and one study on price caps 

because we believed the methods were not sufficiently rigorous.

In addition, we identified and reviewed relevant congressional testimony 

on proposed ticketing legislation. We reviewed the Department of 

Justice’s competitive impact statement and testimonies with regard to the 

2010 merger of Ticketmaster and Live Nation. We interviewed staff from 

the FTC’s Bureau of Consumer Protection and Bureau of Economics, the 

Department of Justice’s Antitrust Division, and the New York State Office 

of the Attorney General, and we conducted a group interview, coordinated 

by the National Association of Attorneys General, with staff from the 

offices of the attorney general of Pennsylvania and Texas. We also 

interviewed representatives of three consumer organizations: Consumer 

Action, the National Association of Consumer Advocates, and the 

National Consumers League; four trade associations: the Broadway 

League, Future of Music Coalition, National Association of Ticket Brokers,

and the Recording Academy; as well as four primary ticket sellers, five 

secondary ticket exchanges and aggregators, one broker, five venue 

operators, three event promoters (who also operate venues), five artists’

managers and booking agents, three major sports leagues, and three 

academics who have studied the ticket marketplace. These organizations 

and individuals were selected based on their experience and prominence 

in the marketplace and to provide a range of perspectives.

We conducted this performance audit from November 2016 to April 2018 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Our investigative staff agent 

conducted all related investigative work in accordance with investigative 

standards prescribed by the Council of the Inspectors General on Integrity 

and Efficiency.
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 58 GAO-18-347 Event Ticket Sales

Michael E. Clements, (202) 512-8678 or clementsm@gao.gov

In addition to the contact named above, Jason Bromberg (Assistant 

Director), Lisa Reynolds (Analyst in Charge), and Miranda Berry made 

key contributions to this report. Also contributing were Enyinnaya David 

Aja, Maurice Belding, JoAnna Berry, Farrah Graham, John Karikari,

Barbara Roesmann, Jena Sinkfield, and Tyler Spunaugle.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101222)
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