FTC's BOTS Act Blitz Raises Stakes for Ticket Resellers

Litigation attorneys Brian Goodrich and Omar Khodor co-authored a Law360 article describing how the Federal Trade Commission (FTC) is harnessing the Better Online Ticket Sales Act (BOTS Act) to ramp up enforcement against ticket brokers and resellers. The BOTS Act prohibits conduct that circumvent online ticket sales platform rules and security measures as well as reselling tickets obtained unlawfully. Historically, the FTC used this law to go after individuals and groups using bots to mass-purchase concert tickets and resell them on the secondary market, but the past two years have seen the government leverage the act's broad provisions to target a range of tools and tactics: multiple accounts, multisession browsers, virtual credit cards and more. In their article, Brian and Omar review the FTC's uptick in enforcement actions – spurred by a March 2025 executive order directing the agency to "rigorously enforce" the BOTS Act – against participants in the ticket resale secondary market and large ticket issuers alike, identifying the practices deemed problematic. The article concludes by presenting the implications of this enforcement shift for the ticket sales industry, and the authors advise companies to screen sales partnerships, reevaluate current operations and formulate a response plan should they receive a government inquiry.

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