On May 7, 2025, the Antitrust Division of the United States Department of Justice issued an RFI for comment called “Anticompetitive Practices in Live Ticketing” (here’s the full PDF). Below is a copy of the full comments we submitted:
Submitted via Regulations.gov
Docket No. ATR-2025-0002
Comment on Competition in the Ticketing Industry
From: Eventably, Inc.
Organization: Eventably | Annapolis, MD
Date: July 1, 2025
As a member of the International Ticketing Association (INTIX) and as a competitive ticketing platform serving live entertainment venues nationwide, I write to support efforts to eliminate deceptive ticketing practices and restore fair competition to an industry that has systematically excluded millions of Americans, including the 61 million Americans with disabilities who face significant barriers to accessing live entertainment.
Excessive and Hidden Fees – Our analysis of consumer complaints reveals service fees reaching 100% of ticket face value, with costs deliberately hidden until the final checkout step. These excessive fees disproportionately harm disabled consumers, who often face limited seating options and cannot comparison shop effectively when accessible tickets are only available through separate, non-transparent booking processes. At Eventably, we prove that transparent, all-in pricing benefits all consumers, including the 28.7% of Americans with disabilities who deserve equal access to live entertainment.
Accessibility Barriers and Consumer Exclusion – Research shows that 50% of disabled consumers who attend live events face access issues, with half of those experiencing booking problems reporting that ticketing companies don’t offer accessible seats as an option. The dominant provider’s monopolistic control has resulted in inadequate investment in accessible booking systems, forcing disabled consumers through separate, often inferior purchasing processes that violate the principle of equal access. With 61 million Americans having disabilities, this represents massive consumer exclusion from the live entertainment market.
Monopolistic Market Control – Ticketmaster’s control of approximately 80% of the primary ticketing market, combined with their vertical integration following the 2010 Live Nation merger, has created a system where venues, artists, and consumers – particularly those with accessibility needs face limited choices. Exclusive venue contracts spanning decades prevent competition and innovation in accessible ticketing solutions, forcing all market participants to accept inferior service that fails to meet ADA requirements and excludes millions of potential customers.
Speculative Sales and Market Manipulation – The dominant provider’s manipulation of both primary and secondary markets particularly harms disabled consumers, who often cannot access fairly priced accessible tickets in primary sales and face even greater barriers in secondary markets where accessible seating is rarely available. This coordinated control across the entire ticketing ecosystem denies equal access to live entertainment for disabled Americans while diverting revenue from artists and venues.
I urge the DOJ and the FTC to adopt comprehensive reforms:
- Break up the Live Nation-Ticketmaster vertical integration to eliminate the ability to leverage venue control for ticketing market dominance that excludes disabled consumers
- Ban exclusive dealing arrangements that prevent venues from choosing competitive ticketing providers offering superior accessibility features
- Mandate all-in pricing transparency and equal accessibility in all booking processes to eliminate hidden fees and separate, inferior systems for disabled consumers
- Require accessible seating availability at all price levels through the same booking process as general admission tickets
- Establish enhanced ADA compliance standards for ticketing platforms with meaningful penalties for accessibility failures
- Create ongoing enforcement mechanisms to ensure equal access for the 61 million Americans with disabilities
Thank you for taking on this critical issue. As a competitive ticketing platform, Eventably abides by the International Ticketing Association’s Code of Ethics and ADA requirements that promote transparency, fairness, accessibility and trust in ticketing for the live entertainment industry. We have proven that competitive markets can deliver superior value to all consumers, including disabled Americans who have been systematically excluded by monopolistic practices.
The American people—all 330 million of us, including 61 million with disabilities— deserve access to live entertainment that is fairly priced, transparently marketed, accessible to all, and provided through competitive markets that reward innovation and customer service rather than market manipulation and consumer exclusion.
Sincerely, Eventably, LLC. Annapolis, MD