STATE OF NEW YORK

OFFICE OF THE ATTORNEY GENERAL

ERIC T. SCHNEIDERMAN

DIVISION OF ECONOMIC JUSTICE

ATTORNEY GENERAL

INTERNET BUREAU

SENT BY OVERNIGHT DELIVERY AND EMAIL

December 7, 2015
Tod Cohen, Esq.
General Counsel
StubHub, Inc.
199 Fremont Street, Floor 4
San Francisco, CA 94105
Aaron Johnson, Esq.
Director of Litigation
eBay Inc.
2065 Hamilton Ave.
San Jose, CA 95125
Re:

New York State Office of the Attorney General (NYAG) Inquiry into the Sale of
Springsteen Speculative Tickets

Dear Mr. Johnson:

The NYAG has learned that ticket resellers may be using StubHubs website to offer
speculative tickets to upcoming Bruce Springsteen concerts in New York. As you may know,
speculative tickets are tickets that resellers offer for sale, despite not having a ticket in hand or
even the right to a ticket. When a speculative ticket is sold, the reseller tries to purchase an
actual ticket, at a lower price, from a different source to provide to the buyer. The reseller
pockets the difference between the price that he paid and the price at which he sold the ticket.
Speculative tickets harm both consumers and the ticket industry. In many cases,
consumers who purchase a speculative ticket do not receive the seats that were advertised and
paid for. In some cases, consumers receive no tickets at all. Speculative ticket sales also drive
up prices for consumers, and often cause widespread confusion and frustration among
consumers, who wonder how tickets can appear on the resale market before tickets are released
to the public.
On December 4th, 2015, Bruce Springsteen announced concert dates for his tour of the
United States in 2016. Tickets for these concerts will not be released for sale to the public until

120 BROADWAY, NEW YORK, NY 10271 PHONE (212) 416-8433 FAX (212) 416-8369 WWW.AG.NY.GOV

December 11th. However, by December 6th, hundreds of tickets to these concerts were listed on
StubHubs ticket resale platform, including for concerts in New York at Madison Square Garden,
the Times Union Center, and Blue Cross Arena. Many of these listings offer tickets for sale at
more than $1,000 per ticket, but some are much higher than that; at the time of this writing, the
most expensive tickets cost more than $2,500 at the Times Union Center, $5,000 at the Blue
Cross Arena, and more than $5,800 at Madison Square Garden.
We understand that StubHub strictly prohibits the listing of speculative tickets. Please
review the ticket listings for Bruce Springsteens upcoming concerts in New York and,
consistent with StubhHubs policies, remove all speculative ticket listings.
We would also like to learn more about speculative tickets and how StubHub combats
them. We therefore ask that you meet with us at our offices to discuss a number of issues
relevant to our inquiry, including:

What dates and times were tickets for Bruce Springsteens concerts at Madison
Square Garden, the Times Union Center, and the Blue Cross Arena first listed on your
platform?
Have you identified any speculative ticket sales in connection with the Bruce
Springsteen concerts at Madison Square Garden, the Times Union Center, and the
Blue Cross Arena?
What is your policy with respect to the posting of speculative tickets?
How are speculative tickets identified?
Once speculative tickets have been identified, what steps do you take to remove the
tickets from your site?
When a seller of speculative tickets is identified, what are the consequences for that
seller?

Thank you for your cooperation. If you have any questions, please feel free to contact
me.
Sincerely,

Jordan Adler
Assistant Attorney General
Internet Bureau
(212) 416-6307

120 BROADWAY, NEW YORK, NY 10271 PHONE (212) 416-8433 FAX (212) 416-8369 WWW.AG.NY.GOV