A San Diego broker and three executives allegedly used account proliferation and IP masking to defeat issuers' technological controls and resell millions of tickets.
Acting on referral from the FTC, the Department of Justice filed a civil complaint against ticket broker REPS & Company, Inc. and three of its senior officers. It alleges the company systematically circumvented the technological controls that ticket issuers use to enforce purchase limits, in violation of the Better Online Ticket Sales Act (BOTS Act) and Section 5(a) of the FTC Act. The complaint seeks a permanent injunction, monetary relief and civil penalties, and includes a jury demand (U.S. v. REPS & Co., No. 3:26-cv-05895-CAB-BJW (S.D. Cal. Oct. 15, 2026)).
The complaint alleges that REPS, a California corporation based in San Diego, uses unlawful tactics to bypass security measures in order to exceed ticket limits set by issuers such as Ticketmaster and AXS, to resell the tickets on secondary marketplaces at a markup. It alleges the company has done so since at least 2022, targeting high-demand events likely to sell out, including concerts, sporting events and theater. According to the pleading, issuers commonly cap purchases at four to eight tickets per buyer, sometimes at an artist's request.
Between January 2022 and October 2025, the government alleges, REPS bought more than eight tickets for at least 83,000 separate events. It alleges the company spent over $1.3 billion to accumulate more than 18.5 million tickets and earned at least $120.8 million in profit on resale. The complaint offers two examples. For a 2023 Beyonce concert at Arrowhead Stadium, REPS allegedly used at least 1,300 accounts to buy 7,624 tickets, for roughly $833,000 in profit. For a 2024 Pitbull concert, it allegedly used at least 700 accounts to buy 5,430 tickets at a venue of about 17,500 capacity.
The complaint describes two principal methods. The first is account multiplication. REPS allegedly employs purchasers, most of them in the Philippines, who use accounts the company controls rather than accounts tied to unique individuals. It allegedly obtains "power of attorney" agreements from employees and partners authorizing it to use their names and addresses, then pairs those identities with REPS-supplied email addresses, phone numbers and virtual credit cards. The pleading alleges as many as 40 accounts were created from a single person's identity, averaging 19 per person. It also alleges SIM banks were used to receive verification codes automatically.
The second method is concealment of location and identity. The complaint alleges REPS used VPNs, rotating proxy services and multi-session browsers to hide its true IP addresses and to appear in sales queues repeatedly. In one alleged instance, purchasers averaged eight browser tabs during on-sales.
Government's legal theory. The complaint rests on two prohibitions in the BOTS Act. The first reaches anyone who circumvents a security measure, access control system or other technological control that an issuer uses to enforce posted purchase limits or to maintain the integrity of posted online purchasing order rules. The second reaches the sale or offer to sell, in interstate commerce, of tickets obtained in violation of the Act, where the seller participated in or could control the violation, or knew or should have known of it. The pleading also draws on the Act’s definitions of “event,” which covers a public event at a venue with capacity above 200 that is marketed or sold in interstate commerce, and “ticket issuer.”
The government argues that Ticketmaster and AXS maintain the kinds of controls the statute protects. Ticketmaster’s site caps its quantity selector at the posted limit, returns “limit error” messages to buyers who exceed it, and verifies account and payment information, according to the complaint. The pleading adds that Ticketmaster’s published purchase policy required each account to be linked to a unique individual and barred the use of multiple accounts to exceed limits. AXS, it says, reserves the right to total purchases made across multiple sessions and to cancel orders that exceed limits.
To show circumvention, the government relies heavily on REPS’s own internal materials, as quoted in the pleading. The complaint describes an “Error Bible” that catalogs issuer error codes and workarounds, and internal instructions to alter address details after limit errors. It also describes account testing aimed at finding “non-obvious” or “clean” accounts, and executive communications about how issuers link accounts through credit card and IP data. When issuers introduced new blocking measures, the complaint alleges, REPS adapted. It cites incidents in October 2023, March 2025 and September 2025, and says the company COO later set a 2026 goal of tying a single proxy to each account to reduce blocks.
The resale prong rests on allegations that REPS resold or offered to resell most, if not all, of its tickets on marketplaces including StubHub, Vivid Seats, SeatGeek and Ticketmaster’s resale platform.
The BOTS Act treats a violation as a breach of an FTC rule defining an unfair or deceptive practice. The complaint says that treatment brings the conduct within Section 5(a) of the FTC Act and the civil penalty provisions of Section 5(m)(1)(A). To support penalties, the government alleges the defendants acted with actual or objectively implied knowledge. It points to REPS’s listing of the Act as applicable on a 2022 audit questionnaire signed by REPS President, to compliance representations made to vendors and lenders, and to the company’s awareness of 2025 FTC enforcement actions against Key Investment Group and against Live Nation and Ticketmaster. Individual liability is premised on allegations that each executive directed, controlled or participated in the challenged practices.
The complaint further alleges that the defendants are violating or are about to violate the law, and that consumers who might otherwise have bought tickets from issuers at face value have been injured. The court has not yet addressed any of these contentions.
The case is No. 3:26-cv-05895-CAB-BJW.