Ireland approves for-profit ticket touting ban
The re-selling of tickets to large events such as festivals or concerts at above face value will finally be outlawed in the Republic of Ireland.
Under the act, a person found guilty of an offence will face a fine of up to €100,000 or up to two years’ imprisonment.
The anti-ticket touting legislation was approved yesterday (20 April) by the cabinet, years after the initial private members’ bill was proposed in 2017 by MPs Noel Rock and Stephen Donnelly.
The 2017 bill won the backing of the previous Irish government in 2018 and was then brought forward in October 2020 by the deputy prime minister, Leo Varadkar but only now will it be published.
The bill will be introduced to Dáil Éireann, the lower house, at the earliest opportunity, and enacted as early as possible thereafter.
Once the legislation is passed, operators of venues with a capacity of at least 1,000 will be able to apply to the department of enterprise, trade and employment for ‘designation’ which will prohibit the for-profit reselling of tickets for that venue.
Event organisers or venue operators may also apply for the designation of events that take place on an annual or periodic basis in the same venue, such as a festival.
“This bill will stop opportunists enriching themselves at the expense of fans, artists and promoters”
According to the legislation, when a ticket is sold for an event that has been designated or which is to take place in a designated venue, the original seller must be given clear information (with the ticket and when advertising) that tickets cannot be resold above face value for the event in question.
Resellers of these tickets must also provide information on the original sale price of the ticket and the location of the seat or standing area to which the ticket entitles the holder to gain admission, according to the legislation.
The new bill does not address airline-style ‘dynamic pricing’ or ticket bundles, the department of trade confirmed to Hot Press.
“This bill will stop opportunists with no interest or involvement in music or sport enriching themselves at the expense of sports and music fans, sporting bodies, artists and promoters,” says minister of state at the department of enterprise, trade and employment, Robert Troy.
“And importantly, fans will have all the information they need to ensure they are not being ripped off. I recognise that sometimes there are justified reasons for reselling tickets above face value, for example, when charities are fund-raising, so allowances have been made in such instances.”
Deputy prime minister, Leo Varadkar, says: “We’re all looking forward to the day we can go to gigs, festivals and matches again. This law gives me hope. We’re planning for a time when live events are possible again. Numbers will likely be restricted to begin with so it’s even more important that people aren’t ripped off and that tickets go to real fans.”
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The likes of Viagogo are actually weak and damaged
How must the smart people at Bessemer Venture Partners and Madrone Capital Partners, the two VC funds that bankrolled Viagogo’s US$4.05bn acquisition of StubHub, be feeling right now?
For Madrone, in particular, it’s been a tough couple of years. As well as losing $150m in the crash and burn of Theranos, they were also the lead investor in Quibi, backing the ill-fated short-form video service to the tune of $200m during the upwards part of its firework-like trajectory.
And then they met Eric Baker.
Much has been written about how the Viagogo/StubHub merger, completed one month before the world shut down, was, in the words of Forbes magazine, “The Worst Deal Ever”.
I’ve written about it myself, on this website – highlighting how the deal appeared wildly overpriced, even before we all became self-professed experts in vaccines and lateral flow testing, and how a combination of regulation and innovation were, in the longer-term, likely to fundamentally disrupt a secondary ticketing “business model” wholly dependent on search advertising and large-scale touts.
Added to that was the spectre of an investigation by the UK’s business regulator, the Competition & Markets Authority, who duly put the merger on hold, concluded that the acquisition created a “significant lessening of competition” in the UK, and subsequently ordered Viagogo to sell-off StubHub’s international operations before integration can complete.
There’s evidence to suggest much of the inventory on Viagogo doesn’t actually exist
Would-be suitors for the international (ie loss-making) parts of StubHub, as well as being approved by the CMA, will be required to run the platform as an uncapped resale service and in direct competition with Viagogo. In the current environment, that sounds a fairly unalluring prospect. Although, as Madrone has repeatedly highlighted, fools and other people’s money can be easily parted.
Meanwhile, and perhaps more alarming for those beleaguered investors, the credit rating of Viagogo’s parent company PUG LLC started to nosedive. They took on an additional $330m in loans, and then, earlier this year, informed regulators in Australia – who’d hauled them over the coals for making false or misleading representations when reselling tickets – that they couldn’t pay a AUD$7m fine due to the catastrophic impacts of the pandemic.
Oh, and Eric Baker reportedly embarked on a property spree in Beverly Hills, completing the purchase of his third mansion in September 2020 for $39m. Presumably, the pandemic not being quite so financially catastrophic for him personally.
And now, as detailed in a Guardian yesterday, there’s evidence to suggest much of the inventory on Viagogo doesn’t actually exist, and that speculative selling – some of it by businesses likely connected to Viagogo itself – is rife.
This could now be the opportunity to step up, to standardise the changes outlined in the FanFair guide
I certainly hope Bessemer and Madrone have digested the implications of Rob Davies’ latest investigation into the bizarre and artificial constructs of this market – and that they’ve studied the February 2021 Phase 2 Final Report from the CMA, which concluded that the value of tickets resold through the UK’s online ticketing platforms in 2019 was around £350m. Somewhat less than the £1.5-2.5bn estimated by Viagogo and StubHub.
As we all wait optimistically for gigs and festivals to return, and for normal life to resume, I hope that promoters, agents, artist managers, venues and primary ticket companies are also taking note, and recognising that, rather than all-powerful platforms, the likes of Viagogo are actually weak and damaged enterprises – and that the UK industry has been greatly empowered over recent years to prevent the exploitation of customers in the secondary market and offer them a better and fairer alternative when it comes to resale.
The wider industry can, of course, choose to do nothing. Shrug shoulders. Say how terrible ticket touting is while failing to enact the fairly simple measures that can help prevent it.
Alternatively, this could now be the opportunity to step up, to standardise the changes outlined in the guide FanFair published back in September 2019, and ensure there’s a wider push to properly communicate how resale works, and that those services are the best they can be.
Viagogo disputes the claims made in the Guardian article. A spokesperson says: “Viagogo rejects the unsubstantiated allegations in the Guardian article referenced in this piece. No evidence was outlined in the article nor was any provided to the company despite repeated requests.
“There is a mechanism in place to raise issues formally either with Viagogo or the regulator. The Guardian chose instead to write a misinformed article.
“Viagogo has strict measures in place to ensure the accuracy and compliance of listings and to prevent fraudulent selling, which are audited annually by a third party.
“In all transactions there is an onus on the seller to agree to certain terms and conditions, which includes the right to sell a ticket.
“Where we are provided with proof from a relevant authority of an abuse of these rules we will investigate and, if confirmed, action will be taken.”
Adam Webb is campaign manager for FanFair Alliance.
Convicted touts sentenced to 6.5 years in prison
A pair of internet ticket touts have been sentenced to a combined six-and-a-half years in prison, in the first case of its kind in the UK against fraudulent resellers.
Peter Hunter and David Smith, who operated as the company BZZ Limited, received four years and 30 months in jail respectively, following an investigation by the National Trading Standards eCrime Team, and trail at Leeds Crown Court.
Earlier this month, jurors found Hunter and Smith guilty of fraudulent trading – for the resale of tickets that were invalid, at risk of being refused or that they did not own, and reducing the number of tickets available to consumers at face value – as well as of possessing an article for use in fraud – for using ticket bots and credit or debit cards under different names.
The pair committed offences between May 2010 and December 2017, making a net profit of £3.5 million in the last two years of fraud alone, buying and reselling tickets to concerts by artists including Ed Sheeran, McBusted, Taylor Swift and Coldplay, as well as to shows including Harry Potter and the Cursed Child.
According to the National Trading Standards, Hunter and Smith used almost 100 different names, 88 postal addresses and more than 290 emails to evade detection, as well as using specialist software including bots, Insomniac Browser, Omni Checker and Roboform and taking steps to circumvent captchas or IP address detection.
“This is an important milestone in the fight to tackle online ticket touts who fraudulently buy and resell tickets to thousands of victims to line their own pockets,” comments Lord Toby Harris, chair of National Trading Standards.
“It’s a fantastic result for music lovers across the UK, and should also send shockwaves through the likes of Viagogo and StubHub”
“Today’s sentences send a strong message to similar online ticket touts: these are criminal offences that can lead to prison sentences. I hope this leads to a step-change in the secondary ticketing market, making it easier and safer for consumers buying tickets in the future.”
Adam Webb, campaign manager for anti-tout group FanFair Alliance, says that the sentences “a major blow to online ticket touts who break the law and rip off the public.
“It’s a fantastic result for National Trading Standards and for music lovers across the UK, and should also send shockwaves through the likes of Viagogo and StubHub whose businesses are dependent upon large-scale resellers.
“By facilitating the activities of online touts, there must be concerns that the platforms themselves are profiting from the sale of tickets unlawfully acquired by their biggest suppliers.
“This should be investigated as a matter of urgency, and lead to action against those platforms if they have benefitted from the proceeds of criminality.”
Viagogo last week announced it had ‘completed’ its US$4 billion all-cash acquisition of StubHub, although the merger still needs approving by regulatory bodies, including the UK’s CMA, before they can operate as one entity.
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Sheeran manager condemns ‘absurd’ resale prices
Ed Sheeran’s manager, Stuart Camp, has testified in court against touts selling tickets for a charity concert for almost 1,000 times above face value.
Speaking at Leeds crown court in the UK, Camp told the jury that he had decided to take action against resellers after spotting tickets for a £75-ticket charity show flogged for £7,000 on secondary ticketing site Viagogo.
No artist fee had been charged for the show, which took place at London’s Royal Albert Hall in March 2017, in aid of the Teenage Cancer Trust.
“I bet none was donated to charity,” Sheeran’s manager told the jury. “This is absurd. We just really wanted to make sure we weren’t in that situation again.”
The defendants in the trial – Peter Hunter (trading name Ticket Wiz) and David Smith (BZZ) – reportedly spent over £4 million from June 2015 to December 2017 buying tickets on primary sites using automated ticket-buying software, or bots. The pair then sold the tickets through secondary platforms for a total of £10.8m. Both men deny the charges.
Following the incident, Camp implemented a no-resale policy for tickets to all stadium dates of Sheeran’s record-breaking ÷ (Divide) world tour, the highest grossing in history.
Ticket sales were limited to a small number of primary sellers, with only resales through dedicated fan-to-fan platforms permitted. Fans were informed that tickets bought through secondary platforms would not be valid and told to bring the credit or debit card used to purchase the tickets to guarantee entry.
“Our theory is that we want everybody to be able to come to a show. We’d rather put on a million more shows for a lower price,” explained Camp.
“Our theory is that we want everybody to be able to come to a show”
“I’d rather keep people happy and people saying ‘you know what, we’ll do that again some time’.”
The manager stated that Viagogo, which last month made headlines for its US$4bn purchase of fellow secondary ticketer StubHub and its reappearance on Google advertising, “ignored” the policy.
However, a Viagogo spokesperson claims the letter “wasn’t ignored”. Rather, says the spokesperson, “we disagreed with his [Camp’s] approach.”
“Our position is, and always has been, that it is unfair to restrict fans’ access to an event just because of where or how they purchased their ticket,” continues the spokesperson. “We now list restrictions clearly at the top of the web page in line with those of the venue and our customers are always protected by our ticket guarantee. However, we fundamentally believe the consumer should be allowed to sell on tickets they either no longer want or can’t use, as part of a competitive market.”
The scheme received criticism from some fans who claimed the regulations made it impossible to shift unwanted tickets.
At the time, a spokesperson from Kilimanjaro Live, who co-promoted Sheeran’s UK stadium dates, said,“Whilst we understand the frustration of someone who is unable to resell and wants to drop the price accordingly to give themselves a better chance of recouping some of their money, unfortunately this throws up more questions than answers.
“From the outset we have tried to find a way to be fair to fans, to facilitate the ethical resale of tickets and to leave as many fans as happy as possible whilst preventing the daily horror stories of them being ripped off by ticket touts profiting from the panic to get a ticket to see Ed. We have undoubtedly had a huge impact here.”
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Tegan and Sara tackle ticket touts
Twin sister indie-pop duo Tegan and Sara made a stand against secondary ticketing platforms that had “unethically gobbled up” tickets for their show at San Francisco’s Sydney Goldstein Theater (1,687-cap.) earlier this week, offering up empty seats to fans on a first come first serve basis.
“Our goal is to ensure that our real fans are in each and every seat, and to prevent secondary platforms from hurting our show,” the pair posted on Facebook prior to the show on Tuesday (1 October).
“As an experiment, tonight we will be offering rush seating for all open seats. This means that we will allow any empty seats to be available on a “first come first serve” basis in return for a “pay what you can” cash donation at the door to the Tegan and Sara Foundation, which works to support LGBTQ+ girls and women.”
After analysing tickets left on secondary platforms, the pair had calculated that over 200 seats at the “technically sold-out” show would remain unfilled.
The band stated they would keep fans “updated on rush seating and ticket availability” of upcoming shows.
Tegan and Sara are playing throughout October and early November in venues across the United States and Canada, before heading to the UK for dates in Brighton, London and Manchester.
TicketOne: touts thriving under named ticket law
Italy’s largest primary ticketing service, TicketOne, has once again criticised national communications regulator AGCOM for its lack of action against secondary sites, highlighting the “significant failing” of the newly introduced named ticket law.
Criticism is levelled at the “foreseeable and forewarned futility” of the regulator’s controversial named ticket law, which was implemented on 1 July. According to TicketOne, the ‘named’ tickets are being sold “widely” on secondary sites.
Additionally, the CTS Eventim-owned company questions AGCOM’s (Autorità per le Garanzie nelle Comunicazioni, Communications Authority) “total lack” of action against secondary sites, following an initial call-to action in March and a follow-up in June, which included a threat to refer AGCOM to the judiciary.
“In light of the documents submitted, and of further concrete evidence immediately available on the sites for anyone who accesses them,” states TicketOne chief executive Stefano Lionetti, “it is not understandable why AGCOM has not intervened – and does not intervene immediately – to crack down on illegal conduct, removing content and shuttering sites, as well as implementing financial penalties.”
“It is not understandable why AGCOM has not intervened and does not intervene immediately to crack down on illegal conduct”
Lionetti states AGCOM is “not exercising the powers granted to it by the Ministry of Economy and Finance,” referencing the stringent anti-ticket touting regulations passed by the Italian government in 2018.
The ticketing site notes that the failure to implement regulations is highlighted by the fact that all cases reported and documented in the initial March complaint were in reference to summer events that have now passed.
“It would therefore now be impossible to fulfil the requests to remove content or shutter the sites, leaving only the possibility of levying fines to mitigate the harm done to consumers, artists and operators in the sector,” reads a TicketOne statement.
TicketOne now urges the timely application of the law in terms of content removal, fines and shuttering of sites, once again not excluding contact with the judicial authorities.
Japan’s ACPC takes tough anti-tout stance
Japanese promoters’ association, the All Japan Concert and Live Entertainment Promoters Conference (ACPC), is calling for a “fairer secondary ticketing infrastructure”.
Following the adoption of Japan’s new anti-touting law, which effectively criminalises touting, the ACPC has issued a statement in which it urges an overhaul of the Japanese ticketing system.
“Ticket touting will not disappear tomorrow,” reads the ACPC statement, entitled ‘Ticket Integrity’. “From better education for consumers to strong enforcement, we will tackle the issue from all angles to help establish a fair ticketing system that truly puts fans first.”
“Ticket touting will not disappear tomorrow”
The association believes that secondary ticketing is among the industry’s “most pressing issues”, as the resale market gets set to reach almost US$15.2 billion by 2020.
ACPC chair Takeo Nakanishi commends the work that the Face-value European Alliance for Ticketing (FEAT) is doing “to encourage better legislation in Europe”, stating that the aim is to establish “a healthy ticketing system worldwide”.
In response, FEAT director Sam Shemtob says the anti-tout alliance “support[s] the ACPC in their work towards preventing ticket touting in Japan at this pivotal time, and are delighted by the impact new anti-touting legislation will no doubt have.
“We are confident that, as the live events industry and governments work together, a fairer ticket resale market can be achieved globally.”
Finding their FEAT: Promoters back new European anti-tout association
Europe’s leading live music professionals have come together to form the Face-value European Alliance for Ticketing (FEAT), an organisation dedicated to the promotion of face-value ticket resale across the continent.
Launched last night at Eurosonic Noorderslag in Groningen, the Netherlands, FEAT will take a continent-wide approach to encourage better ticket resale practices in Europe.
“Governments need to understand speculative ticket resale is an abusive and unethical practice that harms people, and they need to approve laws that make it virtually impossible,” says Neo Sala, FEAT Director and founder of Doctor Music.
The priorities of the initiative include:
- Encouraging better legislation at national and EU level: coordinating lobbying efforts for better legislation to protect fans and artists and encouraging enforcement.
- Connecting live industry professionals: sharing knowledge and building consensus towards a fair and safe ticketing marketplace across Europe.
- Collecting data and research: tracking artist and fan concerns, ensuring their interests are represented and voices are heard.
FEAT has been functioning under the radar for a while. The group is already involved in EU parliamentary discussions on secondary ticketing and has facilitated the formation of a legal group which coordinates activities on ticketing regulation and works in conjunction with search engines.
“We need to get this right as otherwise fans and artists alike will be robbed by thieves”
Initially focusing on legislation and good practice within the live music industry, the initiative later looks to build alliances with the full scope of the live entertainment industry, including performing arts and sports events.
The alliance will be run by Sam Shemtob, a music business specialist who has been active in the UK’s All Party Parliamentary Group (APPG) on ticket abuse for several years, along with colleagues Katie O’Leary and Dominic Athanassiou.
“We need to get this right as otherwise fans and artists alike will be robbed by thieves,” says Scumeck Sabottka, FEAT Director and CEO of MCT-Agentur. “If we all pull this together and get EU legislation to follow our lead, we can ultimately make it work.”
The alliance hopes to bolster the work of movements such as UK’s FanFair Alliance and the Swiss Ticket Check. Such groups have enjoyed considerable success on tightening up ticket resale on a national scale, but have not managed to shake the impunity of global platforms.
The case of secondary ticketing website Viagogo serves as an example of this impunity. As of today, the site was required to implement substantial changes to its business practices following a court order served in November 2018. However, sufficient changes have not been made.
FanFair Alliance’s Adam Webb comments: “Although a few minor changes have been implemented, some of which may add even more confusion for consumers, we would be astonished if the site is compliant with the terms of its court order.”
A full list of the FEAT founding members is below:
Ben Giezenaar – Co-Founder, Greenhouse Talent, Netherlands (Once in a Blue Moon Festival, Justin Bieber)
Christof Huber – Managing Director, Incognito, Switzerland (Imagine Dragons, George Ezra)
Folkert Koopmans – CEO, FKP Scorpio, Germany (Ed Sheeran, Rolling Stones, Foo Fighters)
Kim Worsøe – Director, ICO, Denmark (The 1975, Sam Smith, Disturbed)
Neo Sala – Founder & CEO, Doctor Music, Spain (Adele, Rolling Stones, Bruce Springsteen, Doctor Music Festival)
Olivier Darbois – Director, Corida, France (Christine and the Queens, Justice – produced worldwide, Kraftwerk, Radiohead – promoted France)
Pascal Van De Velde – Founder & CEO, Greenhouse Talent, Belgium & Netherlands (Elton John, Katy Perry)
Peter Aiken – Managing Director, Aiken Promotions, Ireland (Bruce Springsteen, Rolling Stones, Ed Sheeran, Adele)
Philippe Cornu – Founder, wildpony, Switzerland (Muse, Rammstein)
Scumeck Sabottka – CEO, MCT-Agentur, Germany (Red Hot Chili Peppers, Pearl Jam, Lykke Li, Björk, Rammstein, Florence + the Machine)
Vincent Sager – Managing Director, Opus One, Switzerland (Arcade Fire, Iron Maiden)
Anti-Viagogo campaigner ‘helps reclaim £100k’
Anti-Viagogo campaigner Claire Turnham says she has helped disgruntled people claim back over £100,000 in refunds and bank chargebacks in six months.
The founder of the Victim of Viagogo Facebook group started her crusade in February after she says she was overcharged £1,150 trying to buy four Ed Sheeran tickets through the resale site. She finally got a refund after doggedly persisting with her claim and taking her story to the media.
“We continue to hear from ticket-buyers who are extremely frustrated when seeking redress from Viagogo.”
On Wednesday, BBC consumer advice programme Watchdog investigated the activities of secondary ticketing websites – in particular Viagogo and its sale of tickets to Ed Sheeran concerts in the UK. The singer vowed to cancel all tickets to his gigs on secondary sites, and promoters Kilimanjaro and DHP reportedly voided 10,000 passes.
However, while most resale sites refused to list the tickets, Viagogo continued to allow them to be sold. It claimed the promoters were not legally able to cancel tickets, maintained they remained valid, and refused refunds. UK Trading Standards disputes this interpretation of the law, the programme heard.
Fanfair Alliance campaign manager Adam Webb said: “We continue to hear from ticket-buyers who are extremely frustrated when seeking redress from Viagogo, which is why FanFair Alliance has teamed up with Claire Turnham to produce some comprehensive guidance to help them secure a refund.”
Turnham said: “If you are distressed and desperately seeking a refund, I urge you to persevere. It’s not an easy process but it is possible to reclaim your money back. Keep referring to our self-help guide and connect with others for support.”
Recent research by Which? found that approximately half of people who purchased tickets on these sites believed that they were buying from the official ticket seller.
UK MPs warm to ticket resale regulation
Days after culture minister Dario Franceschini declared he would seek to make online ticket touting illegal in Italy, members of the British parliament (MPs) this morning signalled their willingness to further regulate the UK’s secondary ticketing market, with one stating: “The time has come when we have to do something.”
In three sessions, the Culture, Media and Sport Committee heard from MMF’s Annabella Coldrick, Wildlife Entertainment’s Ian McAndrew and You Me at Six frontman Josh Franceschi; Ticketmaster UK chairman Chris Edmonds, eBay/StubHub’s Alasdair McGowan and Paul Peak and the Society of Ticket Agents and Retailers’ Jonathan Brown; and Professor Michael Waterson and Iridium Consultancy’s Reg Walker, respectively, with MPs backing calls for action from those hostile to online ticket resale.
“I’m on your side on this one,” Nigel Huddleston, MP for Mid-Worcestershire, told Coldrick. “The British public are more than happy to applaud entrepreneurs, but there’s a fundamental difference between that and price gouging.
“Being ripped off – that’s what the British public won’t tolerate.”
High Peak MP Andrew Bingham said: “I sat on the all-party group with Sharon [Hodgson MP] in the last parliament, and I took the view then that this market is working and we should leave well alone, but I have to say things have evolved […] and the time has come when we have to do something.”
“Things have evolved and the time has come when we have to do something”
Bingham, however, warned against acting hastily and appeared to suggest the issue still needs to be looked at in more detail. “What we don’t want to do, if we’re going to legislate, is send the industry back to blokes hanging around outside venues shouting, ‘Tickets, tickets, who wants tickets’,” he said. “As legislators, we want to get this right.”
Colne Valley MP Jason McCartney suggested “naming and shaming” promoters and venues complicit in the transfer of inventory from the primary to the secondary market, calling them “the villains in this”.
While declining to name names, Coldrick said there is a “if you can’t beat them, join them” attitude among some artists, while McAndrew revealed he had been “approached often by the ‘big four’ resale sites”. “That’s a proposal I’ve refused on a number of occasions, but I can understand how that might be a temptation for [those] who want to maximise revenue,” he said, “and that’s why I think we need to look at transfer of tickets from the primary to the secondary market.”
Nigel Adams MP, a longtime campaigner against ticket bots and professional touts, asked Coldrick, McAndrew and Franceschi: “What is the solution? Not everybody can do what Josh does, sitting in a shop and selling tickets to fans… What do we need to do?”
“For a start, the law needs to be enforced,” said Coldrick. “The Consumer Rights Act  says seat numbers and rows must be shown on tickets, that if promoters make a clear statement tickets can’t be resold they can cancel them…
“The experience was very positive, and a distinct progression from previous governments’ narrative around the issue of ticket abuse”
“There needs to be a wholesale inquiry into how these tickets are being sold and how they’re being acquired.”
McAndrew added: “We need to see criminalisation of bots, and we need to look at transfer of tickets from primary to secondary. I’d like to think that’s already an offence under existing consumer law.”
Reflecting on the session, McAndrew told IQ this afternoon: “I think the experience was very positive, and a distinct progression from previous governments’ narrative around the issue of ticket abuse, particularly with relation to ticket resale.
“The committee clearly understands the issues around ticket resale and the harm that is caused to consumers. They also understand the opaque nature and scale of the ticket resale business and how the lack of transparency impacts negatively on music fans, and recognise the vast profits and excessive fees generated by the £1 billion-a year-resale business and how virtually none of that goes back into the live music economy.
“I hope today’s session will provoke a more in-depth investigation to the issues around ticketing in the UK.”