J~ j) i-itlJ irtl k ~middotmiddotUdegH rutr u~middotnr ~tn- ot -rf t c (n -t titfmiddot t ftt ~~ -t ~ ~~ middot~ ~ 10 U~ f tfrl ~ fn U1l i 1 ~ 11 ~ (bull( ~ 11oi 1hbullmiddot $( f(rf t middot ti tl t t middot-t -r~-r ~ ti lttoft middot~ ~ fr1n VgtP -~ Uf~ t fift hrlr J ot O O -middot) A ll r r middot1~ 1~t-~ - -~~ middotu1 1 ~ middot Z O~~ ~O~Q ~ ~~e ~ G ~~1lV1r v ~bull~t- lh~e fnI t llt imiddotrrt- 1 ~ 0 tlt11 tt1n l (t tltf ttrU bull t-l n-1 -0~~ ft-t ~ tnr ~U ~nt ~~ t t -n-t ltt- r t ~-ru fZ t lt ~~ n-tt tno ~ n-atr ~~ flt (fttr t~ lt t t 1-ff ~- Lr 1Ul tt-tmiddotu hbullhmiddot bull tlt Hrt Rc flltkf1n-tr tt ftti-f - -r l il l -k~ 111-ttr ~~ft

ENTERTAINMENT INC December 5 2018

Submitted Electronically

Federal Trade Commission Office of the Secretary Constitution Center 400 7th Street SW 5th Floor Suite 5610 (Annex B) Washington DC 20024

Re Online Event Ticket Workshop

Dear SirMadam

Feld Entertainment Inc (FEI) is the worlds leading producer of live family entertainment spectaculars including Marvel Universe Live Disney On Ice Disney Live Sesame

Street Live Monster Jam and Monster Energyreg Supercross Each year FEI productions appear in stadiums theaters and arenas to entertain millions of people throughout the United States and the world FEI also self-promotes the vast majority of our events and is thus actively engaged in the event ticket market at a significant level

FEI believes that the Commissions planned workshop is a useful follow up to the recent Government Accountability Office (GAO) report which identified various issues of interest in the area of online event ticket sales including the use of BOTS speculative ticketing and deceptive websites by some resellers as well the question ofallowing restrictions on transferability of tickets in the primary market eg paperless ticketing The GAO report reinforces the fact that consumers are more likely to have problems and complaints with the secondary ticket market than with the primary eg more transparent white-label search results

Our business is bringing quality live entertainment to consumers and a key element of that is the fair and efficient sale and distribution of tickets As a business we depend upon the revenues generated by ticket sales to pay salaries purchase advertising and pay all of the other costs associated with our productions Our objective is to price tickets at a level that maximizes both attendance and revenues and to ensure that the ticket process is secure and convenient for our consumers However as a producer oflive family entertainment FEI also recognizes the need for

8607 Westwood Center Drive Vienna Virginia 22182 (703) 4484000 Fax (703) 4484100 wwwfeldinccom

Federal Trade Commission Online Event Ticket Comments Page 2 of 2

and is committed to offering tickets at accessible price ranges to ensure customers from various income levels can afford to see our shows

Most tickets for FEI events are offered through sale to the general public directly or through ticketing companies such as Ticketmaster However for each FEI event some number of tickets may be offered for pre-sale to dedicated customers to and through sponsors and through venues and other partners Tickets may also be issued by our promoters for use by FEI employees performers families friends and guests

FEI fully supports efforts by the Commission and other federal agencies to prevent and reduce any activities by ticket resellers that make it more difficult for consumers to purchase event tickets from primary ticket distribution sources at the price set by the entities responsible for the event and the tickets ie promoterproducer artist teamclub arenastadium Chief among these would be improved enforcement of the Better Online Ticket Sales Act We also support measures to ensure that consumers know when they purchasing tickets from a reseller

Nevertheless FEI recognizes and supports the existence of a legitimate secondary market for event tickets At the same time we firmly believe that the role of restrictions on transferability such as paperless tickets should be decided by market forces Preventing the use of paperless tickets or other transferability restrictions would significantly interfere with the currently competitive marketplace Ifcertain types of ticketing or restrictions are not accepted by the market they will inevitably fail

Thank you for the opportunity to submit these comments We look forward to participating along with other stakeholders in the Commissions workshop and the discussions regarding these issues

Sincerely

Stephen Payne Vice President Public Affairs