STUBHUB Statements to CBC News
On Oct 5, 2017, at 10:18 AM, Dave Seglins wrote:
Cameron,
We regret StubHub has declined our request for an on-camera interview.
I’d like to extend the invitation again, and give you some specific questions we’d like
answered on-camera, or if you decline, in writing.
As background, CBC News/Radio-Canada and the Toronto Star are conducting an
investigation into the global on-line scalping industry. It is a collaboration with the Guardian
newspaper (UK), BBC and other media partners.
You indicated to us in an email last night that “BOTS are primarily used to attack primary
ticketing sites….{and they} are in the best position to comment.”
StubHub is one of the world’s largest ticket reseller websites now operating in more than 47
countries and is a major profit earner for its parent company eBay. Our investigation has
uncovered evidence to suggest many bulk scalpers use StubHub to resell tickets obtained
through BOTS and StubHub is actively enabling, profiting from and providing financial
incentives to these mass resellers.
We ask the following questions of StubHub given its position as such a large player and as
a global advocate for the “fan experience:”
TOP SELLER PROGRAM
1. What is StubHub’s “top seller” program?
2. What are the minimum requirements to become a top seller for StubHub?
3. What background checks and due diligence requirements does StubHub impose on its
top sellers before acceptance into the program (ID, passport, criminal background, proof of
citizenship, proof of business location)?
4. How many “top sellers” does StubHub have in each of Canada, USA, UK, Europe?
5. What are the benefits to becoming a StubHub ‘top seller?’
6. Are StubHub employees assigned to manage relationships with top sellers? If so, what
are their responsibilities?
7. What percentage of StubHub’s overall ticket sales transactions are resales by “top
sellers?”
8. What “sell fee incentives” does StubHub offer top sellers - and why?
9. How is it that StubHub markets itself as a “fan to fan” reselling platform, but offers
software tools and profit incentives that facilitate the uploading, inventory management and
resale of thousands of tickets by industrial scale bulk scalpers?
10. What benefits does StubHub extend to “partners” as defined under the Top Seller
program?
11. Have you entered into any partnerships -- formally or informally -- with your high-volume
ticket resellers? If so why?
12. If so, how many?
13. What is the nature and intent of these partnerships?
14. Are you aware of any of your top sellers claiming to be engaged in formal partnership
with StubHub?
15. Does StubHub ever advance credit or pay Top Sellers in advance (i.e. before payment
has been made by the ticket end purchasers)? If so, why?
16. Why do StubHub’s global websites make no direct mention of - or link to - the
company’s StubHub Pro or StubHub “top seller” programs?

 17. How are the bulk ticket management tools afforded to top sellers through StubHub Pro
and TicketUtils software (inventory and seating management) in any way considered in the
interests of the “fan” experience?
SELLER INFORMATION DISCLOSURE
18.
Why does StubHub in North America keep reseller information on its website secret
from the public and fan customers?
19.
Why does StubHub UK post seller information identifying businesses scalping
tickets - but won’t afford the same information to customers in Canada and the US?
20.
Why does StubHub not post the original face-value price of a ticket on its resellers’
offerings so fans can evaluate the value and price difference?
21.
What is the company’s position on proposed legislation to govern ticket reselling
that is currently under review in Ontario?
22.
Has StubHub lobbied the Ontario government on the draft law and, if so, what
reforms or changes has StubHub sought?
STUBHUB RESPONSIBILITY
23.
What responsibility does StubHub have for monitoring, detecting, and prohibiting
resale of tickets the company suspects - or ought to suspect - were obtained by StubHub top
sellers employing “Bots?”
24.
What steps does StubHub take to determine whether the bulk quantities of tickets
being sold by StubHub “top sellers” are obtained legally? (not using bots, fake ID, multiple
credit cards in multiplicities of identities)
25.
How many StubHub “top sellers” have ever been disqualified from using StubHub
due to questions surrounding the legality of their acquisition of tickets?
STUBHUB TICKET FRAUD/CANCELLATIONS
26.
How many tickets sold through StubHub have been cancelled or denied entry by
venues or other authorities over the past three years in each of the following: UK, US,
Canada?
27.
What were the reasons for these imposed cancellations/denials of entry?
28.
In instances where your customers unwittingly purchase tickets that are ultimately
cancelled by venues or other authorities, what is your policy?
SEARCH WARRANT EXECUTED ON STUBHUB (London, UK)
29.
Why did StubHub UK refuse to cooperate earlier this summer with a voluntary
request by the UK’s Competition and Markets Authority to disclose information about top
sellers?
30.
Has StubHub now provided the UK’s Competition and Markets Authority with
details of its top sellers as a result of the CMA warrant executed on StubHub’s London this
summer?
31.
What materials did the CMA seize during the raid (numbers of computers, hard
drives, documents, phones)?
32.
Does StubHub refute any of the sworn claims made by investigators in support of
obtaining the CMA warrant? If so, which claims?
33.
What, if any, legal action has StubHub brought to challenge the validity of the CMA
warrant?
We hope StubHub will consider granting us an on-camera interview some time in the next
two weeks, to allow us to meet our deadlines.

 If not, we’d like detailed answers to each of the specific questions above no later than 4 pm
on Thursday October 12th.
Please confirm you received this.
If you’d like any further clarification of our questions, please don’t hesitate to call me directly
at XXXXXXXXX.
Many thanks in advance,
DS
9:39 AM October 12, 2017 from StubHub (Via Email)
Hi all,
Thanks again for looking at StubHub’s perspective here. Please find below statement from
StubHub in regards to your questions. Please confirm receipt and when you expect the piece
to run.
StubHub is a marketplace that enables people to buy and sell tickets safely and securely
online. As is a common practice within a marketplace business, StubHub has programs that
incentivize trusted sellers to sell their inventory on our platform, including lower fees and
technical support. StubHub holds all sellers to a very high standard and requires they follow
all relevant laws. To ensure customers the best fan experience, StubHub operates an
industry leading trust and safety operation that has a long history of working with law
enforcement to help identify and work toward eliminating any fraudulent or illegal activity on
our site. While thousands of transactions occur on StubHub every day, far less than 1% of
these transactions run into an issue. These rare issues are covered by StubHub’s industry
leading FanProtect™ Promise which has been the hallmark of our platform for over ten
years.
StubHub agrees that the use of bots to procure tickets is unfair and anti-consumer. StubHub
has always supported anti-bots legislation and encourages policy makers to look
comprehensively at the host of factors that impact a fans ability to fairly access, buy, resell,
or even give away tickets in a competitive ticket market. StubHub believes that public
policies should be designed to encourage safe and secure ticket transactions. For more
information on StubHub’s stances on proposed Ontario legislation please see our attached
letter to Ontario Attorney General, Yasir Naqvi.
Cameron Papp
StubHub Communications Manager
Thursday October 12, 2017 (Via Email) from Dave Seglins
Cameron,
Thank you for the statement and the partial information you’ve supplied.
However, we regret that you’ve provided only two paragraphs of information and failed to
respond in any way to some specific, key questions.
So we pose them again, in hopes you can provide a direct response to the following:

 1. What background checks and due diligence requirements does StubHub impose on its
top sellers before acceptance into the program (ID, passport, criminal background, proof of
citizenship, proof of business location)?
2.

How many “top sellers” does StubHub have in each of Canada, USA, UK, Europe?

3.
What percentage of StubHub’s overall ticket sales transactions are resales by “top
sellers?”
4.
Why do StubHub’s global websites make no direct mention of - or link to - the
company’s StubHub Pro or StubHub “top seller” programs?
5.
Why does StubHub in North America (compared with StubHub UK) keep reseller
information on its website secret from the public and fan customers?
6.
What steps does StubHub take to determine whether the bulk quantities of tickets
being sold by StubHub “top sellers” are obtained legally? (not using bots, fake ID, multiple
credit cards in multiplicities of identities)
7.
Has StubHub now provided the UK’s Competition and Markets Authority with details of
its top sellers as a result of the CMA warrant executed on StubHub’s London this summer?
8.
Does StubHub refute any of the sworn claims made by investigators in support of
obtaining the CMA warrant? If so, which claims?
CBC/Radio-Canada, Toronto Star, the Guardian, BBC and other media partners continue
this investigation. We remain eager for an on-camera interview with a senior representative
of StubHub to best understand and explore the issues we’ve raised as we prepare our
stories for publishing and broadcast.
Please confirm receipt.
Given we’ve already posed these questions, we ask that you provide a more driect and
detailed response to the above by tomorrow at 4 PM ET.
Many thanks in advance,
DS

Friday October 13, 2017 from Dave Seglins (via email)
Cameron,
Could you please confirm receipt and acknowledge our request (Stubhub comment by 4 PM
today)?
(I'm cc'ing your communications colleagues at eBay as well in case you are travelling once
again and are not receiving our emails).
Thanks. Hope to hear from you soon.
DS

 October 13, 2017 (via email)

Got it, Dave! Our statement below and letter to Mr. Naqvi covers all of StubHub’s stances.
Thanks again for reaching out for our perspective on this.
Cameron Papp
StubHub Communications Manager
Friday October 13, 2017 - 9:47 AM
Cameron,
Thanks for confirming receipt.
To be clear - you've not answered our specific questions (the 8 you originally ignored, which
we resent to you yesterday).
Absent a direct response, I trust StubHub/eBay will have no objection to us characterizing
StubHub as refusing to answer any of those 8 questions.
I'd ask you again to reconsider offering us an interview with one of your senior people, which
would be much easier and more helpful to the public as we seek to thoroughly examine
these issues affecting the fan experience and the global ticket resellers market.
As a courtesy, I want you to also know that as we proceed with preparation of our stories,
you can anticipate that we (CBC/Radio-Canada, Toronto Star, Guardian, BBC) expect to
deliver you some additional follow-up questions in the coming next or so.
Please, again, give us the courtesy of confirming receipt.
Respectfully yours,
DS
OCTOBER 30, 2017
Cameron,
I’m following up on our correspondence earlier this month, with some important additional
questions.
As I explained, CBC News/Radio-Canada and the Toronto Star are conducting an
investigation into the global on-line scalping industry. It is a collaboration with the Guardian
newspaper (UK), BBC and other media partners including the ICIJ (International Consortium
of Investigative Journalists).
We still hope your company will open to considering a sit down interview so that we and our
viewers and readers can better understand StubHub’s operations, and the issues weraise
below.

 Failing that, we would appreciate written responses to our questions below by the end of the
week (5 PM Friday November 3rd).
Our questions are as follows:
JULIEN LAVALLEE
1. What is StubHub’s relationship with Julien Lavallee?
2. What due diligence did StubHub conduct before accepting Julien Lavallee as a ‘Top
Seller?”
3. What volume of sales does Julian Lavallee make through Stubhub in each of Canada,
US and the UK?
4. We’ve obtained 2015 information drafted by Julien Lavallee in which he describes
expanding his own company operations into the United Kingdom and (eventually) Europe in
which he describes being in a “partnership” with StubHub. What is the nature of StubHub’s
“partnership” with Mr. Lavallee?
5. Do you have any concerns about his use of your website for his ticket reselling
business? If so, please detail those concerns.
UK INVESTIGATORS
6.
One UK anti-scalping investigator has told us that StubHub UK officials clearly told
him that Julien Lavallee represents one of your company’s “biggest global” re-sellers.
Where does Mr. Lavallee rank as a StubHub seller in terms of the volumes of his gross ticket
sales?
7.
The investigator has told us in an on-camera interview that he alerted StubHub
officials to suspicions Julien Lavallee was acquiring tickets to UK events illegally, but was
rebuffed by StubHub officials. What do you say to that?
8.
One UK investigator, in viewing internal Lavallee company documents detailing his
2015 plan to expand into the UK in “partnership” with StubHub, is now calling for a criminal
investigation into StubHub’s potential complicity in criminal behaviour. What is your
response to this?
STUBHUB’S “Top Seller” / STUBHUB PRO
9.
A number of entertainment industry insiders have expressed to us in interviews that
StubHub is knowingly complicit - and facilitates - activities of mass scalpers who acquire
tickets via questionable - if not illegal - means. What comment does StubHub have to these
allegations?
10. Why does StubHub make no mention on its consumer/fan website of its “Top seller”
program or its relationship with mass ticket resellers?
11. What percentage of StubHub overall ticket sales - are made by “top sellers”?
12. How does your “top seller” program (including Sell Fee Incentives: Discounts to sellers
with a minimum of $250,000 in sales) NOT contribute to the multiplication of bulk scalpers in
the market?
13. Have you ever removed a “top seller” from your site for breaches of any terms and
conditions of the program? If so, please provide statistics and context for what types of
actions have triggered removal from the program.
14. Is your February 2017 Top Seller Handbook, as of today’s date, the most up to date
version of your “top seller program” rules? If not, can you please provide us a copy that is
more current than the following:https://data.stubhub.com/files/Top%20Seller%20Handbook
%20February%202017.pdf
15. How many tickets sold through StubHub have been cancelled by venues or other
authorities over the past three years in each of the following: UK, US, Canada? What were
the reasons for these imposed cancellations? In instances where your customers unwittingly

 purchase tickets that are ultimately cancelled by venues or other authorities, what is your
policy?
PUBLIC POSITION ON BOTS
16. How is it that StubHub takes public positions in favour of anti-bot legislation - yet
accepts the upload and resale of massive quantities of tickets by sellers on your website?
17. Where do you think many of your “top sellers” are acquiring their tickets?
18. What background checks and due diligence requirements does StubHub impose on its
top sellers before acceptance into the program (ID, passport, criminal background, proof of
citizenship, proof of business location)?
19. What due diligence does StubHub conduct to evaluate the source of tickets resold on
its website?
20. How many “top sellers” does StubHub have in each of Canada, USA, UK, Europe?
21. Why does StubHub in North America (compared with StubHub UK) keep reseller
information on its website secret from the public and fan customers?
22. What steps does StubHub take to determine whether the bulk quantities of tickets
being sold by StubHub “top sellers” are obtained legally? (not using bots, fake ID, multiple
credit cards in multiplicities of identities)
23. Has StubHub now provided the UK’s Competition and Markets Authority with details of
its top sellers as a result of the CMA warrant executed on StubHub’s London this summer?
24. Does StubHub refute any of the sworn claims made by investigators in support of
obtaining the CMA warrant? If so, which claims?
25. Experts and industry watchers we have consulted have raised concern ticket reselling
sites such as StubHub are vulnerable to being used for money laundering purposes. They
suspect criminals can coordinate bulk resale and purchase of blocks of tickets posted for
sale at high prices, enabling them to “clean” large volumes of money using sites like
StubHub to “legitimize” and create false receipts for illicit funds.
26. What knowledge does StubHub have of any money laundering activities on its
platform?
27. Are these legitimate concerns?
28. Have authorities in any of the US, Canada or UK raised this issue with the company?
If so, what has the company done to address it?
29. Does StubHub maintain its position expressed before UK parliamentarians last year
that your company has no obligation to monitor and investigate individuals using your site to
resell tickets?
Thank you for your time and consideration.
We look forward to hearing from you. Please do not hesitate to contact us if you need any
more information or clarifications.
And please confirm once you’ve received this.
Yours truly,
DS
OCTOBER 31, 2017
Cameron,
Please confirm that you and StubHub have received our questions of October 30.
Thank you,

 DS
3:01 PM from StubHub (via email)
Got them. Thanks for the added context here, Dave. Our statement and letter to Mr. Naqvi
covers StubHub’s stances including the extent to which we work with trusted sellers.
Thanks again for reaching out for our perspective on this.
Cameron Papp
StubHub Communications Manager