Vermont Legislature SmartTranscripts:

[Emily Carris Duncan (Member)]: Yeah.

[Michael Marcotte (Chair)]: Morning, everyone. This is the Vermont House Committee on Commerce and Economic Development. It is Friday, 02/06/2026 at 10:17 in the morning. So we're here to start taking some testimony. I think we're going to start with H733. We have David Hall from the Secretary of State's office. David, if you'd like to join us.

[Herb Olson (Member)]: Sure.

[Michael Marcotte (Chair)]: Morning. Good morning. Good morning. Good to see you all again.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: David Hall, director, business services division, secretary of state's office.

[Michael Marcotte (Chair)]: Good to have you back in the seat again.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Glad to be here as always. So

[Michael Marcotte (Chair)]: seven thirty three is a regulation of franchise agreements. One thought that I've had why I've asked him is, we really don't know right now who's a franchise. We don't I'm not sure who the franchisors are, the franchisees are. I guess the first question is, franchisors, if they're doing business in the state, are they required to required to register with the Secretary of State's office?

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: If they're they're doing business here, absolutely, yes. I guess the

[Michael Marcotte (Chair)]: the doing but doing business, does that means if they're if they're only have franchisees in the state, is that still doing business in the state?

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Sure. I mean, you know, I this this seems like one of those questions that should just have, like, a really easy answer, and, of course, it doesn't. And that's because, you know, coxotically, the statute doesn't say what it means to be doing business in a jurisdiction. In fact, it does the opposite, and it says, just because you do these types of things doesn't might mean that you're doing business, but it might not. And and then it's got a list of things that alone don't constitute doing business in the state, it's it's so it's not an affirmative. And, you know, to be perfectly honest with you, it's it's it's not advice that we give out to the world, because it's legal advice. It triggers the duty to take some sort of action out in the world, and that's the kind of thing an attorney tells a client, yes or no. I mean, generally, we probably just wanna nudge people to be registered. So the way it works for a we call it a foreign business, and that means not domiciled in Vermont. That means another state, another country. If you're a foreign entity, you've been formed in some other jurisdiction, so you legally exist in Massachusetts or wherever else. But you can go to the other states. You want to do business in those states. Could do so with lawful authority. You would file, for a for a certificate of of good standing or or not excuse me. A certificate of authority. It can be called different things in different places. You'd give us your information, what your name is, what your address is, all the usual stuff. You would actually have to give us a certificate of good standing issued by your state's jurisdiction so that we would see that it matches up and that you do exist and you're in good standing there. Then we would come and approve that and let you do business here. So if you are doing business here, yes, you need to come to us and file

[Michael Boutin (Member)]: as a foreign

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: domiciled LLC, corporation, whatever, to have lawful authority to act in the state. If you don't, there's enforcement available through the AG's office, including the loss of access to courts, penalties for every day that you're not signed up. So the requirement is there across the board if you're doing transacting business in Vermont, you have to register with us. If you don't, you're not acting a lawful authority and there are consequences. I was gonna pull up the provision in case you're curious about what it means to do or not be doing business. Is that something you're interested in? So this is a good example under subchapter eight, foreign LLCs section forty one thirteen, activities not constituting transacting business.

[David “Dave” Bosch (Member)]: I don't I don't know

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: if you wanna see this on

[Michael Marcotte (Chair)]: the screen. Basically, like, David and.

[Edye Graning (Vice Chair)]: Do you have a link or if you're else doing like You

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: know, the way that it's been working with everything going through, and I'm not sure if I ended up giving the link or not. Let me I apologize for the technical Yeah. Pickup. I don't think I have it.

[Michael Marcotte (Chair)]: Sorry.

[Edye Graning (Vice Chair)]: Address?

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: David.p.hall,hall,@Vermont.gov.

[David “Dave” Bosch (Member)]: Okay.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Zooming in. So before I can I mean, I'll say it it works like this from the language is pretty much the same across entity types, but remember that they're you know, each type has its own has its own framework? It's

[Michael Boutin (Member)]: that's

[Michael Marcotte (Chair)]: all. Sounds all. Okay.

[David “Dave” Bosch (Member)]: Unmute it. All of my audio, I hope,

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: is now off. And let's see.

[Herb Olson (Member)]: Where's the statute?

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: It's amazing how quickly you forget how to use Zoom.

[Michael Marcotte (Chair)]: So you're a little out of practice.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: It's terrible. The rest of government is all on Teams, and I'm just sort of

[Edye Graning (Vice Chair)]: see the share button. And the ability to select either sharing your old desktop screen or the application. Okay.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Well, all that just to bring you back to your own statutes and show you 11 VSA four one one three. So, you know, a, your prohibition foreign LLC may not transact business in the state until it obtains a certificate of authority from the secretary of State, except as provided in doing business or transacting business shall mean include any act, power, or privilege exercised or enjoyed in the state by a foreign policy. I mean, I I guess that's your affirmative, but that doesn't really tell you much. You know? And then c, this is where it gets interesting. Among others, following activities without MORE do not constitute transacting business for the purpose of determining whether they have to register with us. So maintaining, defending, or settling any proceeding. So, you know, there's a court action or something like it. Holding meetings of members or managers or carrying on other activity. So you come for your board meeting in Stowe. That doesn't make you doing business. Maintaining bank accounts. Maintaining offices or agencies for the transfer exchange and registration of its own securities or trustees or depositories with respect to the securities. So selling through independent contractors. So

[Michael Marcotte (Chair)]: Yeah. Could a franchisee be considered independent contractor?

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Or is the no. Damian doesn't even do that anymore. A good question. So soliciting or obtaining orders, whether by mail or electronic means or through employee agents, if they require acceptance outside the state for the contracts. Creating or requiring indebtedness in real or personal property. Securing or collecting debts or enforcing mortgages or other security interests in property, owning real or personal property, conducting an isolated transaction that is not one in the course of repeated transactions of a like nature or transacting business in interstate commerce. So I can't I mean, have some familiarity with franchise agreements from my former life, but can't give you a clean yes or no. It depends on how you set it up, how many contracts, how's the contract framed, who owns the property, who directs the employees, is it just the licensing agreement where they're just, I don't know, deliveries? Who makes the deliveries? Do they come into the state from another place? Do you own the trucks? Do you own the products? I don't know. There's all kinds of factors. So my honest answer is, should they register? I'd like them to under this slate of tests. I don't know.

[Herb Olson (Member)]: Might that be a question for you, but do you know whether any other states that regulate franchise agreements have a specific definition about doing business? I do not. Sorry.

[Jonathan Cooper (Member)]: Thanks, David. I think I grasped the nebulousness of this. But the following activities without more. Mhmm. Is the phrase without more a what's that doing there? Sure. And does that have anything to do I'm just wondering what that is in there for and if that will help us understand anything in any way. Fair question.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: I don't have a definitive answer. I I I would say, you know, if if it's a one off, you buy one building,

[Herb Olson (Member)]: you don't regularly do business,

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: you just occasionally do. You do just one of these things or maybe two of these things, but you don't do anything else. So it's not, you know, unfortunately,

[Jonathan Cooper (Member)]: it's a subjective analysis. It could be more activities not among these 11 enumerated

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: here. Could be more than just what's there. And the more you do of those and or other things, maybe there's a weight of evidence that piles up. I see. Thanks.

[David “Dave” Bosch (Member)]: So when we

[Michael Marcotte (Chair)]: and even if they are franchisor, there's no way of us knowing that they're a franchise unless it's a, well known franchise.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: I mean, if you're asking about the underlying records that we hold and whether those would indicate that they conducted activities or franchise or no. The reason being, so there's a slate of data that you supply when you register with the Secretary of State's office. It slightly varies sometimes among the types, but for the most part it's your name, your address, you can supply your principals if you want to, officers, shareholders, some entity types that stuff's required, but most not. There is a purpose section in our module, in our workflows, because most of the state statutes require that you state the purpose for which you're formed, but there's sort of a universal loophole, because you can form a business, most business kinds, for any lawful purpose. So that, at the end of the day, maybe doesn't tell you much. Right? We have it set up so that the way you communicate your purpose to the world for us is you select a next code in AICS. You can select more than one. So theoretically, could people choose that or list that as their business purpose? Sure. Are they required to know is it a reliable all encompassing data set that would be helpful in that regard? No, not right now.

[Jonathan Cooper (Member)]: Does that language apply only to foreign limited liability companies? Are all foreign registrations LLC? What language and What you just read to us for four zero one.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Business doing business or not doing business?

[Jonathan Cooper (Member)]: Yeah, that seem to be

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: provision is just for foreign LLCs, but there are comparable provisions for other foreign corporations.

[Jonathan Cooper (Member)]: Okay, that was just an example.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Sure, exactly. But the criteria requirements, indices, they are roughly the same across. They're all built on case law ultimately accumulated over the years that sort of built up factors without being definitive.

[Michael Marcotte (Chair)]: And the same is on the franchisee side. You don't know what business in the state is the franchise if they're franchisee as well. Same.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Same situation with purpose. You know, I I I don't know how often you guys hang out in, you know, like, the business records, but it's a it's a it is a minimal amount of information, you know, frankly. There are obviously, within our purview because of other statutes, more much more specific registration requirements that have much more substantive data. So telemarketers, data brokers, amusement ride operators. I mean, that's a different ball of wax than just the business that's transacting or doing activity in Vermont and has to, therefore, register in the generic business registry.

[Michael Marcotte (Chair)]: We wanted to understand franchise experience or involved in the state and how many franchisors, franchise franchisors, franchisees. Mhmm. What is that possible through your system? Is it possible to create a positive check when any new business forms and and then when businesses have to be registered, your annual registration, is it difficult to create that checkbox?

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: So, you know what, I think I like to say or I've learned maybe in this position with respect to IT projects is that technologically, almost anything is possible. You know, it's just a question of time and resources That's true. If that's something that becomes part of our charge, can we build it? I'm sure we could. I think there's different ways to do it. You know, one one Mhmm. Model is freestanding module. It sounds like that would be overkill if all you wanna know is who is who. Another is you just like you suggested, I think you could just add a checkbox at the point of initial filing or at the point of periodic reporting. So I wanna just not necessarily demystify, maybe clarify what the reporting requirement looks like and what we get. So for the major types of entities that are recognized in Vermont, so I'm thinking like LLCs, corporations, nonprofits, LLPs, and then we also have mutual benefit enterprises. There is not a lot of those. We we have, you know, the initial filing. And if you're domestic, that's how you actually create that evidence you filed the initial filing. It doesn't exist until you do so. And then you have an annual reporting requirement, the purpose of which really is just to check the information that's on record. And you can make an update at that point if you need to. It's a relatively minor process. It's really quick, not very expensive, but it is an annual check-in. Except for nonprofits, those are every other year, but probably not who we're talking about in this case. So what I want to stress is that would capture, if it's initial filing and or periodic report, that probably captures I don't know the exact numbers, but I'm guessing 95% of the for profit entities that you would want to capture. There are a handful that do not have periodic reporting requirements, and so it would and those are cooperatives, partnerships, assumed business names, those are one time five year filings. Would a franchisee set something up just under an assumed name? Maybe. I I wouldn't advise it, but people don't always get advice. I would recommend an entity structure, but you never know. So that would be a potential gap there if it was just set up under an assumed name, not under some entity structure, or if they curiously chose an entity structure that wasn't subject to it. So LLP is a realistic possibility. But they have an annual reporting requirement, so take that one off the table. Some kind of a co op, probably not going to happen, but

[Michael Marcotte (Chair)]: Probably the vast majority is going to be annual reporting.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Yeah. I would say so. At this point, the new businesses that are formed are upwards of 8590% LLCs. So

[David “Dave” Bosch (Member)]: Okay.

[Michael Marcotte (Chair)]: So, committee, I know we've walked through seven thirty three. It's hard to imagine doing anything in the realm of regulation without first understanding what the universe is in Vermont. And I think maybe a good first step would be to require Secretary of State's office, franchisors and franchisees, that's the box that they are, that's what they do, how they put their businesses with the law. Don't know that we'll find out what kind of franchise it is, but I think it gives us an idea of how many are here. I don't know how how deep we can go, but we need to go to understand what we're looking for.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: If I may, I'd love to take one big step up with you think about what this and the future of our division might look like in the sense of what kind of data do we want to be collecting from people? Some of it mandatory, maybe some of it's voluntary. We've talked. I've talked with a lot of you over the years in different capacities, an interest in self identified businesses that are woman, let's say, just as a way of example. And so I raise all this because it goes to where do we collect this data? How do we present it? What actually is it? Where does it live? And when you file a formation filing or initial filing for a foreign, it you know, for when you form an LLC, like, you're creating the entity, but it's a very small amount of information. And I I would like the opportunity to just, like, reflect on whether something like a checkbox like that is actually part of your formational document or if it's just a data point that lives beside it in the system. Do you know what I mean? So it's not actually in your articles of organization, but it is data that we collect, hold, publish, push out into the world, and it's searchable and sortable. And over time, I can only anticipate that that that universe might grow. And if it does, I'd be loath to clog up formation filings and initial registration filings with all that stuff. I'd rather it be part of your electronic record, which is how most people use it anyway. Mean, nobody comes to my office and searches a filing cabinet for your LLC. They go online. But I don't know if that changes the drafting. I don't think it changes the legal provision. I'm just thinking from a technical and policy path forward, how do we frame this? So I just want to put that on the table. We can talk about it more if you want. I guess committee, is that that seemed like

[Michael Marcotte (Chair)]: a way to move forward on franchise piece is to actually see if we can find out who's that what the world is and from home. Think franchisors, franchisee. Think it makes sense.

[Herb Olson (Member)]: Okay. So

[Michael Marcotte (Chair)]: we'll chat with Rick and maybe if you can work with Rick and think about it, David, know, how your thoughts on how to best move forward to get the information, that would be great.

[David London (StubHub, Government Affairs)]: Happy to do that. I can

[Edye Graning (Vice Chair)]: be checked in today. Okay.

[Michael Marcotte (Chair)]: Perfect. Any questions for David before we release it? Thank you, David. Sure. Happy to be here.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: He's glad to be back.

[Emily Carris Duncan (Member)]: You're still glad to come back.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: I love coming back. I do avoid making eye contact sometimes in the hallways because some people forget that I don't work here anymore and they ask me to do things. You can ask me an amendment for like, well, no.

[Emily Carris Duncan (Member)]: I mean, I could.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Alright, well, if you have other questions, of course, I'm happy to pop over. I'm just across the street.

[Herb Olson (Member)]: Great, thank you. Otherwise, enjoy your weekend. Thank you too, David.

[Michael Marcotte (Chair)]: Now we'll switch to H512, regulation of event ticketing markets. We have people here from StubHub and ticket policy form. So David, would you like to join us first? Sure, absolutely. Thank you. Thank you for coming up.

[David London (StubHub, Government Affairs)]: Chairman, rank member. No. It's great. Thank you for taking the time to to talk about this issue. You know, today, just wanna touch base quickly on who StubHub is for those that might not be familiar, and then maybe talk about three quick points in the legislation that that we think are important. For those not familiar with StubHub, we were born twenty five years ago out of simple fan frustration, a sold out show and no good way to get tickets that were available. Our founder was on Broadway on a date, looking to get tickets to the Lion King. And the way he did had to do that really felt him made him uncomfortable, right, trying to buy those tickets on the market at the time. And when he looked at the market, he also saw another challenge on the flip side of the coin. Right? All too often, we buy tickets to events two, three, four, five, six months in advance. And when life happens and plans change, trying to sell or give those tickets was really a local issue. Right? You had to find family, friends, coworker that could take those tickets. You know, I'm from New England originally. My experience is probably similar to a lot of Vermonters. Right? I remember growing up going to a Red Sox game, driving down the two hours to Boston, and you'd walk around the stadium, right, and you hear tickets, tickets, and you've tried to deal with those people. And maybe you found a ticket at the right price, and then you went to the turnstile, and you did this hoping it worked. Sometimes it didn't. And sometimes you went there and you couldn't find a ticket. So maybe you went to a museum or you went to lunch and then you drove back to Maine where I'm from or back to Vermont. And so the challenges that he saw was was the ones I think people here and and elsewhere saw. And so what StubHub is is it's a platform where we just connect buyers and sellers to tickets. And so we don't own the tickets, and we don't set the price of the tickets. It's kind of like a the way I explain it is it's an eBay for for tickets specifically. Right? What that means for Vermont, we have 6,000 users last year, here in Vermont. I'd also note that for Vermont specific events, that more than 50% of those buyers came from out of state. So either they came here for an event, they had a hotel, went to bars, restaurants, that sort of thing, or maybe they were here on vacation. And as a lot of people do, when they're on vacation, they come to our website and they say, hey. I'm going to be in Montpelier or Burlington on these dates. What events are taking place there that I can get tickets for? And so for Vermont events, we're able to to bring people from out of states and get people to to fill those seats. Two quick things on on StubHub, and then I'll get to legislation I think is important to to note as well. 90% of our events here in North America have a ticket under a $100 available. North of 60% have a ticket available for fifth for under $50. Fraud is also very rare on our site. Looking at our North American stats, it's 0.2% of orders that ever have a problem at the door. And so what we set what SubHub essentially able to do is take that uncomfortable process that I talked about, whether that's Red Sox or or or Broadway, move it online, inject consumer protections. So we have a fan protect guarantee. And so fans are able to get tickets for for people they don't know. They're able to do so safely, transparently, and do something that that's that's what we say is is fan forward. So we're not a luxury platform, and we've been around for twenty five years because people have keep coming back to our sites because they get a ticket at the price they want, and the ticket gets them in. And that, I think, is the two most important things that probably we're we're all looking for. As it relates to the legislation itself, I think it's important to note on the front end that we support the goals and the intents of this bill, and there are provisions in here that we have long supported, and are are part of our policies. So one, as it relates to the speculative ticket ban that's in the legislation, so that would prohibit the sale of tickets that you don't have physical or constructive possession of. That's against our our policy and something we we support. The we spent strong action on deceptive websites. Right? Those websites that confuse fans, deceive fans. You should go there to a website and think you're buying from an official box office when it's not. So we support provisions like that in the bill. Three points we think we'd like to make on that. One is as it relates to those deceptive websites, the language that's proposed, we are concerned that it's just overly broad. So what I note is that the way it's written, they would be difficult for legitimate platforms like StubHub to even advertise to our customers who the show is or where it is. I don't think that's the goal of legislation. I think you wanna defend things that are deceptive. We have worked with states in probably nearly a dozen states right now to pass deceptive website language. Connecticut's a good model. We just think there's some technical changes to tighten that up to address the needs. The biggest challenge we see in the bill, maybe unsurprising, is is the the price gap provision in the bill. We recognize the the the the instinct and and how appealing that is. The concern is that what we've seen both through research and in real world evidence is that when you put the plate price caps in place, you're not changing the market. You're moving the market. So you're you're preventing regulated businesses like StubHub from putting in the price collapse, but then all of those tickets move to whether that's, you know, classified ads, whether that's social media, Facebook Marketplace, TikTok, believe it or not, Instagram. And we've seen fraud go for x in some of these places where price gaps are in place. And so it doesn't because we have the consumer protections, it really doesn't help the consumer. It hurts them by moving the market to to fraud. I know there's been a lot of talk about the main bill. I am from Maine. I'm a Maine evangelist, so this is really gonna pain me to to talk about. It's important to note that the main bill is the exception and not the rule. When you look at again, because of what StubHub did and other companies followed moving that that unregulated make, unregulated market to a regulated market, a lot of states repealed their price caps. Right? So Florida did it in '20 in 2006. Minnesota, Connecticut in 2007. I don't think a lot of people are talking about the fact that in 2024, Massachusetts repealed their price cap. Just last year, Connecticut looked at a robust ticketing bill. Price caps was included. They removed it before passing it through the house a 147 to zero. So, yes, a lot of states are looking at it. The trend seems to be to repeal or to strip those provisions. We think that's important to note. And, again, it's because when you start digging deep into it, the goal of it is not what's achieved with it. Last thing I'll say, I think, you know, I talk about price caps. When states are removing that, it's not that they're not looking at the challenges or the problems within ticketing. Exactly the opposite. They are looking at it, and they're just seeing more robust ways. And I think there's other provision states are looking at that's not included in the Vermont bill, that could be improved. And I apologize. I'm gonna read this to make sure I I I get it right, and I picked some some red and blue states here. For example, Utah in 2019, looked at anti retaliation measures so people can't be retaliated against for reselling their tickets. Very important, especially in today's world where Ticketmaster is really trying to expand their monopoly into the resale market. Also, making sure fans can't get denied entry simply because they bought a ticket on a secondary platform that we're seeing happen. Utah then in '23 put in disclosure requirements. They did deceptive URLs. They increased their bot enforcement, something that's not in the Vermont bill that we think would be great. And they put in refund requirements for fans, which we think would be a great add to this bill. 24 bipartisan legislation, bots again. They put all in pricing so that fans the first time they see the price, it's the price they end up paying. That's something we implemented in 2014, tried to do. We think it's important to do statutorily. They banned deceptive websites. They also did refund language. And the reason I say this is a great example, democratic governor Polis signed that bill. When that bill was signed, it was signed at Red Rock's iconic US venue. Colorado Perg was there. Other stakeholders were there. They really addressed the the concerns in the industry. Just last year, Oregon did a really robust stakeholder process, included stakeholders, independent venues, that sort of thing. They've attacked they went after bot enforcement and deceptive URLs, again, in a way that we think was was helpful. So we think there's good, strong, import important provisions that can be added to the bill. Again, what I'd say on the the set of URLs is a is a technical change. And, again, we just we're really concerned, and there's a lot of evidence and happy to get into it, whether that's Ireland or France or Australia or other where. I'll use one last example on price gaps in Ontario. They passed a 50% price gap in Ontario in 2017. They realized it was unenforceable and drove people to the black market. They repealed it in 2019. So I think that's some of the challenges that I think they were well intentioned. It just became became a challenge. So, I know that's a lot. I'm happy to take any questions. But, again, I do wanna reiterate that we hope to to work with you, and there's there's strong provisions in this bill that that we support.

[Monique Priestley (Clerk)]: Yeah. Thank you so much. I do I mean, all the examples that you just gave, I really definitely if we're gonna consider any of those, wanna make sure that we hear from Vermont menus on those, especially tracking consumer protection bills in Colorado. I'm not sure that we want to align with everything that's

[David London (StubHub, Government Affairs)]: been going

[Monique Priestley (Clerk)]: on. Doing a search last night for the infamous string dusters, Paramount had a sale for those tickets of $73 They were listed on StubHub for $120 as the best deal. I'm just curious, like,

[Emily Carris Duncan (Member)]: with your call for

[Monique Priestley (Clerk)]: transparency and saying that you don't want to be deceptive and extractive of our small venues. I'm just curious how you can justify the best deal being on sub SubHub for those tickets for a 120 when tickets are available from the Paramount directly for $73. And so couple things on that that I just and I'll I'll address it in detail. But, you know, a lot

[David London (StubHub, Government Affairs)]: of times we get those questions. Right? X ticket that's available on your site, that's higher. One thing I always highlight to people on the front end is if it's there, it's because it hasn't sold. Right? That's why I note that the sale price in so many of our shows are are less than that. Right? If the seller determines what price I'm gonna try to sell it at, it's a buyer that ultimately determines the price. If I want to go to that show and it's and it's and I'm looking for tickets, I may see a price that's very high and decide not to buy. I'll look at other tickets and find a lower price. Right? So everything that you see that's on the site that's extremely high is there because it hasn't sold. And by the way, it may never sell or never sell at that price. It'll get dropped down. You said it was the best deal. I forget the exact quote. Best best deal.

[Monique Priestley (Clerk)]: Yeah. That seems very deceptive.

[David London (StubHub, Government Affairs)]: And what I just say is base because we have the information that's on our site, and so that's that we look at what's available on our on our site on

[Emily Carris Duncan (Member)]: that.

[Monique Priestley (Clerk)]: It was on StubHub.

[David London (StubHub, Government Affairs)]: Yeah. Yeah. No. But, like, it's the best deal on our site. And I think just like by the way and that's no different than if you look at no. But if you look at a re if if you look at a retailer look at a retailer, like, a lot of times, they you know, Target may say this is the best this is the best deal we have or it's it's marked down, and it might be higher at Walmart or Amazon or whatever. Right? And so I don't think it's any different than, in some cases, a retail market,

[Michael Marcotte (Chair)]: so to speak. Sure. Everyone so, Tony, I think you had your hand up.

[Anthony “Tony” Micklus (Member)]: I did. Take me back to the fraud. You'd mentioned 0.2%. So what is your mechanism for collecting reports of fraud? Is it something that the how does how do you even find out that there's fraud?

[David London (StubHub, Government Affairs)]: Yeah. So when I so it's 0.2% of orders, right, have a problem at the door. So we hear from our customers when they go to the door and they have a problem with their tickets, they call Step Up. So Right? And say, hey. I bought tickets from you. It didn't work. And so that happens. And and why I put it the other thing I'd I'd just note on that. Right? We sold 40,000,000 tickets last year. As I note, that means if it's a one in a million chance it happens, it happens 40 time on our site. Right? And so, yes, there's gonna be anecdotal evidence of challenges, but it's not the norm. We wouldn't be in business and have repeat customers for twenty five years if that was the norm, and we do a number of things to prevent fraud on the front end as well.

[Anthony “Tony” Micklus (Member)]: So if I could follow-up on that, in listening to testimony of a lot of our venue operators here, oftentimes, they'll just let them in anyway. So you wouldn't know about those. So my question would be, you know, now do you offer a refund to the to the ticket holder if you find out it's fraud?

[David London (StubHub, Government Affairs)]: Yes. So so one, chances are they did call us. Right? Maybe they got in, but before they got in, they're not happy about not being let in. Their first call is is to is to stub up. And what I note is, you know, on I think this is why also why it's so important to go after the deceptive websites and the bad actors because I bet their fraud numbers are a lot higher than ours. So for example, in order to one of things we do to try to prevent fraud on the front end is the the seller does not get paid until the buyer gets in. So if you bought that ticket a month ago, you will get the ticket. We essentially hold the funds. And if we find out there's a problem there and you don't get in, we the seller doesn't get their money. They can be fined up to they can be penalized up to two x the cost of the ticket. And if it's a real problem, they'll get banned from our site. So we create disincentives in the system to prevent that's just one example of what we do to prevent fraud from happening on our site. I I I don't want this to be that I don't think what the venues are saying is is accurate. I think it I think what they're saying probably does happen. What I'm saying is when you look at legitimate platforms like StubHub, we're doing so much, and the numbers show that there's decreased fraud that our concern is we think that's why you should go after the deceptive websites and really attack what where the problem is and just be concerned about about provisions that may like like the price gaps that may move customers into markets that are more fraudulent.

[Anthony “Tony” Micklus (Member)]: Yeah. I'm a one more

[David London (StubHub, Government Affairs)]: Does that does that answer your question? I don't wanna be just I don't want you know, if it's if it's too vague, please let me know.

[Anthony “Tony” Micklus (Member)]: No. No. I I just will end with this comment is that what we've heard from our venue operators at the door, they give them they give them new tickets. So why they've they've got into the show. Why would they have

[David London (StubHub, Government Affairs)]: an incentive to call stun them?

[Anthony “Tony” Micklus (Member)]: And that's and and you don't need to answer that question. That's just you know, what what I'm trying to illustrate, I don't know how accurate those fraud numbers are. And and let me let me

[David London (StubHub, Government Affairs)]: dig into that to see if we can get better info, and I'll talk to our product folks and happy to follow-up. What I would just generally say about human nature is they are very as you know, you'll probably get more constituents unhappy with you calling you than than those praising you. No no different from us where we certainly hear from folks that that have challenges. And so, you know, the the the consumer is is is quick to to pick up the phone.

[Emily Carris Duncan (Member)]: To follow-up on Tony's point, I'm searching the Step Up website.

[Michael Marcotte (Chair)]: I'm

[Emily Carris Duncan (Member)]: in the customer service portal. I'm just First, it took me quite a while to even find a phone number. I know that chat service is possible, but it's actually not even on the first page. So I'm curious how the inflow of that information for unsatisfied customers is happening. So I'm imagining if I'm on the fly in the moment and I'm having issues with my tickets, it's going to be a lot of searching, lot of page moving, and a lot of really trying to find some very small print to find the actual phone number that I can call and get that in person immediate help that I need. So can you walk through what is the process in which you're intaking all of this information?

[David London (StubHub, Government Affairs)]: Yeah. And and one thing to note, don't forget that people who has bought a ticket from StubHub have communicated with us not just on the website. Right? So we've sent them information on how to transfer the tickets and things of that nature. And and so and I'm happy to get to exactly what you know, if in that process, I where we tell them, hey. And if you have a challenge, here it is. Yeah. Whether that's in the you know you know, because because the consumer the consumer might well, is probably if, you know, if you have a challenge at the door, instinct your is probably not to go to the website, but to go to your communications that you've had with StubHub in the process in this I'll call it the sale process, broadly speaking. So, you know, that's probably where they're getting a lot better information. Yeah. Take care.

[Michael Boutin (Member)]: So I also went on to your website and checked it against the Flynn, regarding kinky boots, which I feel like we should do a field trip. That being said, you know, on their website, after fees are assessed, it's a $100 for a balcony seat ROF. And on StubHub, it was 140. I'm not overly concerned. Part of me is not really concerned about the markup as much as the disclosure of it. Cause I'll be honest, if I was looking at this $140, I'm probably not going to go A $100, that's a different story for me. It may not be a lot for some people, but for me, 40 is like two

[David London (StubHub, Government Affairs)]: meals. And percentage wise.

[Michael Boutin (Member)]: Right. And so you have a problem with the the increase, like or or how much we're allowed you're allowed to charge. What about a full disclosure stating that technically these tickets are available for a $100?

[David London (StubHub, Government Affairs)]: So one thing I'd just note on that, again, they're not our tickets, and we don't have the price. We we're not aware of the the price paid. And while it's easy to say the Flynn in this specific case, what we see a lot as well in in live event ticketing, where it's going, we see more of is dynamic pricing. So think of pricing like, an Uber or an airline where you know that if you're in Seat 13 A, you paid x, and the person next to you may have paid a different price. So what we the the the only person that knows what they paid for that ticket is the consumer. We wouldn't the ticket's not ours, and we didn't purchase it, and we don't have insight to what that cost is. So we went so stuck so StubHub wouldn't it's not like we bought it from the Flint, so to speak, and we're reselling it. We wouldn't be able to to verify that that ticket was for x. Now listen. I I I mentioned, hotels and airlines. We would love an open distribution system where we could verify all of those tickets just like they do in hotels and in airlines so we could help verify some of these tickets. The challenge becomes that the primary ticketing, whether that's Ticketmaster or anyone else, they don't wanna share that information. And so that's the challenge we face is they block us out in the system unlike what you can do with airlines and and hotels and things of that nature.

[Jonathan Cooper (Member)]: John. So it sounds like part of what we're dealing with is StubHub is not interacting with venues, and much of the testimony we've taken has been about venues and their experience of seeing fraudulent and deceptive websites that are either mentioning an extraordinary markup, something sort of ridiculous. But there's an element of this bill about prohibiting speculative ticket sales, in which the ticket is not in the possession of any individual. We're trying to manage that. And I think what I'm sort of picking up from this testimony is that part of what we're looking at is an exchange that someone's hoping to get for a ticket they will not be using, that they've listed. Like, I've paid whatever I paid. I'm hoping to get this amount of money. I'm curious if I can hear your thoughts on where speculative activity begins and ends from StubHub's perspective.

[David London (StubHub, Government Affairs)]: Yeah. So speculative tickets are prohibited on our policy on our website via via our policy. And I think with speculative tickets, the important thing to note here, and and this legislation does it, is you often think of the the ticket in your possession. The important part is that it's in your physical or constructive possession. And the reason I say that is, the easiest example is if you are a season ticket holder, Right? The tickets may not be out yet, but you know that in six months when you see the schedule that your cousin's getting married that weekend, and so you list it on our website, you don't have the ticket in your hand yet, but you obviously have an ownership for lack of better expression, of of that. So that's so I think that's the key because I think sometimes when we talk about speculative tickets, it's kind of looped in even if you don't have the physical ticket, and that's just inaccurate.

[Jonathan Cooper (Member)]: And from from sub hub's perspective, if an individual acquired a ticket from a fraudulent website that was artificially inflated, etcetera, they had no knowledge of the venue's pricing through just ignorance or deceptive practices. Does StubHub have a way of flagging that? Like Yeah. Here isn't like, is there some way that that individual who was defrauded or who fell, I should say, prey to deceptive practices, is there any way for is there any role that the plays in addressing that situation prior to that and when then into a list for sale? I'm curious if that's an area where you have any

[David London (StubHub, Government Affairs)]: Yeah. So two pieces to that. Right? The the the the activity on the front end, let's say it was purchased, I'll say, fraudulently or illegally. And then on the flip side, it's someone that may have purchased that ticket. Right? So on the front end, if we do if we're made aware, we do investigate and look into whether that was if it was done it was purchased illegally, certainly, we take action in that in that, and you can get kicked off our our website for it. Right? So we we prevent that on the on the front end and and and do what we can, and and there's mechanisms to try to look at that. Right? You know, listen. Let's say I'm gonna make up an example. You've never sold a ticket on our website, and then all of a sudden, you're trying to sell 3,000 World Cup tickets or something like that. That may ping us something that's, like, get the the you know, it it pings it it's a it's a it's something that's a anomaly, so it still gets flagged. And, again, I just wanna reiterate, if you purchase it illegally via a bot or saying that that we're aware, that that's banned. On the fraudulent side, on the Right? I've heard stories of people that, hey. You know what? There's a problem with the tickets. StubHub found out three, four, five weeks in advance, and this is where I get back to our fan protect guarantee. Our goal is not to refund people. Our goal is to get them in the event. Right? We are obsessed with that. And so the first thing we do if there's a challenge or we see there's a problem with that ticket, we'll go on our website, we'll purchase it, and we'll say, hey. You know what? We just got you equal or better better tickets. Here's your upgrade. Right? That's where the majority of what I'll call challenges, how they get resolved. And then in the rare occasions where you get to the door and you have a problem, we still try to do that, and then we consider this a failure. But if you really have a problem and you don't get into the show, you can either get a 100% of your money back or a 120% as a as a voucher. Thanks.

[Abbey Duke (Member)]: Addison? So let's say I want to buy tickets to a show, and I do a Google search and a bunch of things show up. Do I know that is a reseller? As a consumer, how would I know that StubHub is reselling if it's

[David “Dave” Bosch (Member)]: anybody, the

[Abbey Duke (Member)]: main place

[Emily Carris Duncan (Member)]: to get tickets?

[David London (StubHub, Government Affairs)]: I also wanna look at the website. I I think it says resale somewhere on there. I'll double check that. But I I'll say this as well. Fans fans wanna get the a ticket to the show or the con of concert or the the game at the price they want and that ticket to go in. It's just like, you know, some people buy on united.com, some people buy on bookings.com, or some people buy on kayak.com. Where the purchase the ticket is purchased or if that's a sale or a resale, most consumers, it's not something they're concerned about. And so they wanna get the ticket at the right price and and get in to the show. I'll also note we have a lot of partnerships, with different organizations where they list directly on our site. So while the vast majority of our site and I should note 99% of sellers on our site are fan sellers, even for big events. So Taylor Swift, for example, 83% of sellers on our site for Taylor Swift were first time sellers. So it really is largely fans. And so, you know, it it's it's really fan to fan selling those those tickets in the large part. Monique?

[Monique Priestley (Clerk)]: Yeah. So I was just wondering, because you guys are incentivized for kind of the the resale price, and I know you're you in your when I asked the first question, you didn't set that price, and that makes sense. But you're still making a percentage off the price. And so I'm just curious, like, as far as going off Rutland's question about the disclaimer kind of thing, I'm curious if when somebody lists something for resale, if you would be supportive of a disclosure from that reseller where they have to put in the original price that they paid for it, if they put a link into the venue that they bought it from, and have that shown on the ticket to the person who's buying a thing that also says there may still be tickets available at the original venue where the sticker was bought. Not

[David London (StubHub, Government Affairs)]: surprisingly. Right? That was in the details of right. A couple of things on that. One, if if you if the consumer has to put it in there, how do we verify that that's that's accurate? Right?

[Monique Priestley (Clerk)]: Sure. Yeah. I mean,

[David London (StubHub, Government Affairs)]: with Putting putting and and and putting and this is a challenge too. For us, I'll be honest with you, when you say, like, putting the actual ticket in there, here's the challenge. Right? How often do you buy a ticket four months in advance? And I think especially in bigger shows that are, like, for example, with Ticketmaster, they won't send you the ticket until twenty four, forty eight, seventy two hours in advance. So you can't upload the ticket to verify it because there is no ticket. Right? And with the dynamic pricing, it's really hard to verify because the same ticket, depending on when it was purchased, is is is TBD. So I think we'd be happy to work with you on something that that works. I just wanna flag there's some challenges there logistically, especially in cases where the ticket doesn't exist yet. And I'll give you another perfect example of where this can get challenging in the kind of bigger picture of of fly event ticketing. If you are a season ticket holder, for example, for the New England Patriots, part of your, deal might be that you have access to tickets first before the vet before a concert comes there. So they could list that ticket for sale. They know they're gonna have access to it, but they don't even have a receipt yet. But it's theirs because contractually there, they have it. And I think that's where people are really surprised. I think we all get that fan club members get access beforehand or you get the you've got the right credit card. You can get it before the general on sale. Federally, the general account, the GAO and the state of New York has looked at this. What people are really surprised to hear is that it can be anywhere from 10 to 46% of tickets are what goes to the general public. The rest are held back for insiders. We so there's a large number of tickets before general on sale that are already in the market. So a lot of times, those are on our site. People will say, how could SubHub have access to tickets before they go on the general on sale? And the reality is it can be north of half. It could be 90% of tickets that are available before general on sale. We think one thing that would be important is requiring disclosure of how many tickets are available at general on sale. So one, so fans know that it's a 10,000 seat stadium or a 4,000 seat stadium, but only a thousand are available at the general on sale. 3,000 are already out there in the market. And that's a disclosure. But long story short, I you know, happy to work with you on that. I just wanna work on some specific challenges, but but happy to work with you.

[Michael Marcotte (Chair)]: So thanks for coming in, representative

[Herb Olson (Member)]: Herb Olson. Having trouble understanding or like help me understand, I think you said a statement earlier in your testimony that your problem with a cap of any sort, I guess, is that it doesn't make the market, it moves the market. And I'm thinking about that and tell me if I'm wrong, sort of assumes that some company like, good actor company like you wouldn't be able to really do business, and so you're not gonna be offering that, and therefore it moves to that actives. And I'm wondering if that's a comment on the level of cap as opposed to cap at all. And that gets to, what's a reasonable cap? Does it cover reasonable cost of what you're doing? So that's my question.

[David London (StubHub, Government Affairs)]: No, that's fair. And I'll just point again to Ontario that did 50%, put it into law and repealed it two years later, because there's an enforcement challenge here too, right? So it's enforcement and moving the market, But on the market specific Can I ask Yeah? Yeah.

[Herb Olson (Member)]: Yeah. Did the Ontario scheme go into effect so they knew that it was moving to bad actors?

[David London (StubHub, Government Affairs)]: Yeah. So it it the the the law passed in 2017. They repealed it in 2019. So they had two years of, you know, two years of of evidence, and, you know, that's for the committee to decide if that's enough or or or not, but that's that's and that was at 50%. We as far as moving the market, if it's you know, I'm you know, I'm a big for me, I'm a big rustic overtones fan that they rarely come. They probably don't anymore come to where I live. If they were to come, I'd be passionate about going to that event. Right? And a lot of the live events people are passionate about going to. Maybe it's because that the you know, you're going to the Red Sox game and Olson is pitching. Maybe you're from California and the Giants are in town. So what we're just generally dealing with are events that people are excited to see and people love. And so when you take that their value, what the buyer sees as the value varies. What as I like to say, my my wife likes country music. You couldn't pay me to go to that show, but she would pay, you know, maybe 25% more than what's there. So what what the value is is really hard to determine in what we what we sell because because it's experiences. And, again, when you look at when you look at Ireland, when you look at Australia, when you look at France where they have price gaps, the market, they they've had the Bank of Ireland has put out warnings that say, hey. Careful of scams and fraud because they're not available on the legitimate I mean, just just, just this week, the California AG had to put out a press release for the Super Bowl to say, be careful of scams. Right? And that becomes even more prevalent when there's a price gaps.

[Herb Olson (Member)]: Can I follow-up? Because, again, I think you're saying the market is gonna move to bad actors, But isn't that only the case if you're not in the business, if you don't continue to do business? And that strikes me as you're thinking that a particular price cap isn't enough to make to do this.

[David London (StubHub, Government Affairs)]: No. No. And I apologize. I see what you're saying now, and I I miss I didn't answer that that that question correctly. Let's say there's a $100 ticket, and there's a 10% price cap. StubHub, as a regulated market, as a business, we will not sell that ticket for a $120. Right? But the market, the demand supply and demand economics say that ticket is actually worth or could sell for a $150. There will be people that then move to Facebook Facebook Marketplace and Craigslist ads and classified ads and TikTok and Instagram, and they'll say, you know what? I'm not gonna sell that ticket at a $110 on StubHub. I can go over here on Facebook Marketplace and sell it for $1.50 because it's it it they're not enforcing that. Right? And then what happens is that's where the market moves, and that's where fraud and scam says, you know what? We see the markets at $1.50. StubHub's selling that at $1.10. They're gonna place those tickets on sale at a 125. So you think it's real but not a good deal. And we've seen people sell hundreds of the same ticket on Facebook Marketplace, and then the the the seller just disappears from from Marketplace. So it's I'm not saying that from a StubHub perspective. We couldn't do business, though I think there's serious challenges there. What I'm trying to focus on is the consumer and that the market when I say the market, the the demand will move over to places that don't have, like, a fan protect guarantee like us. It will it will go back. It will take the street scalping that I talked about, the Red Sox game, move it to the twenty first century with online scams and fraud. And and by the way, that's not theoretical. That's what we've seen in other places, and we have, you know, specifics that we can we can point to on that.

[Herb Olson (Member)]: Thank you. I still have questions here. Thank you. Emily?

[Emily Carris Duncan (Member)]: I have two two questions. On that, I'm curious to know if in those situations, did you see a decrease in your market share in the areas that have the Institute of Prints out?

[David London (StubHub, Government Affairs)]: So let me let me go back and and check because a lot of unsurprisingly, because price caps don't exist in the you know, broadly don't exist in The United States, and I do US work, I can you know, I'm hesitant to comment on market share in Europe that I've just I don't work on, but I'm happy to Yeah. Or Canada. Or or Canada. I'm happy to get that get that information. I'm just I don't wanna be evasive. I just wanna make sure I get you the right information.

[Emily Carris Duncan (Member)]: Appreciate that. And my other question is, when folks are because you guys don't do the selling, the tickets, so you don't set prices for So the when the person is uploading or the whoever is uploading the ticket, do you require for proof of purchase or proof of confirmation in that process?

[David London (StubHub, Government Affairs)]: So the again, the challenge is there's cases where they don't have it, and this is where it goes back to the speculative tickets. It's so important to have the constructive possession as well because there are cases again, I use that that that, season ticket holder that may not have the receipt yet or have the now that being said, we do we do investigate when we're aware, and we do a lot of things on the front end to prevent fraud. But there just are cases where a perfect example. Oasis came to The US, I think was last year. And a letter went out to congress that said, StubHub, these tickets are not on the general available to general public. These are fake speculative tickets, and congress should should do something. We looked into that, and then we we were able to show congress that actually bears season ticket holders and others had constructive rights to those tickets, and they weren't speculative tickets. They were actually real tickets because they had the the as part of their agreement, season ticket holders. I agree. So that's where the the challenge becomes is that it is a it's we would love to be able to verify. We think open distribution is the way to do it. Just like, again, look at airlines. Ticketing is essentially two phases. One, you have the back end, which is the ledger that says, hey. Section one zero two row e c 12 is is is purchased, and then you have the retail side, right, where you're purchasing. We would love from the retail side to be able to verify the back end. The problem is is that the primary level, unlike other other places where you want to distribute your prod your your your merchandise or or product to multiple sellers, primary ticket a lot of times includes exclusive contracts that don't allow you to do that. And they don't allow us to tap into their system like Major League Baseball does, like other airlines do, and that would be the solution. We would love to be able to verify those speculative tickets. But if the primary ticket issuer is not willing to let us use technology to verify that the ticket has been purchased, that's where it becomes a challenge. So we wanna work with the primary ticket sellers to say, just like Major League Baseball, just like other industries, let us verify that that's that that's a a ticket.

[Emily Carris Duncan (Member)]: Yeah. I mean, take your point. I am curious about the example that you use for the seats and ticket holder. I'm assuming that somewhere in their contract or somewhere in some sort of confirmation, there is something that says You have priced tickets at the stadium from whatever. So I'm curious as a potential fix to be able to actually because there are other things. If you wanna do a rebate, you gotta supply proof of purchase. So I'm curious if that is something

[David London (StubHub, Government Affairs)]: I'd just note that the text in this legislation would ban exactly that, speculative tickets. So I actually don't think there needs to be a larger fix that's in the current text because the current text would ban

[Emily Carris Duncan (Member)]: Oh, I'm not talking about speculative ticket. I'm just talking in If somebody is uploading a ticket to the site, assuming that they legitimately purchased that ticket from the original venue or the ticket software, that they would have some sort of confirmation to upload and say, Hey, Yeah.

[David “Dave” Bosch (Member)]: So to

[David London (StubHub, Government Affairs)]: put it into scale, we sold 40,000,000 tickets in 200 countries. There are big venues, small venues. There's sports. There's whatever. To verify at scale that what is entered there is is is a is a it could be a challenge. Again, I think we do other things to prevent fraud. That's why our North American numbers are at 0.2%.

[Michael Marcotte (Chair)]: Abbey and Michael.

[Abbey Duke (Member)]: From my perspective, I'm less concerned about price gaps than I am about consumer notification and consumers understanding that it's a reseller versus a primary seller. And so I've been playing around with my daughter is a Ryan fan, and it turns out he's at the Bank Of New Hampshire Pavilion in May, so maybe we'll go. And so I was looking at, if I was a consumer buying tickets, would I understand that StubHub is a reseller? And both StubHub and a couple of your competitors, on the first page in small font at the very top, it says, StubHub is the world's top destination for ticket buyers and resellers. Prices may be higher or lower than face value. I think that's clear. In that little font, once you're like, oh, look, May 29, 7PM, see tickets, you don't ever see that again. And I think that's the place that you would know that it's a reseller. And so I'd be interested in And I'm guessing that that's a requirement somewhere in the country or that you need to have seems like a good assumption. And I'd be curious about what it could look like to have maybe a reseller notification that goes deeper into the process so that you know. Because most people, you go to this first page, you're looking for Luke Bryan. You're not looking at the top of the page. So that's something I'd be interested in. If you'd be amenable to that, if you have thoughts on that, where it says See Tickets, you click on see tickets. Could there be a notification that continues into the process saying, we're a reseller. Hey, just so you know, we're a reseller. So it's not

[David London (StubHub, Government Affairs)]: And like I said, it's not out there on the first page. Our goal is not to deceive customers. So if if if you think there's ways to improve that, happy to talk to you. The one thing and this is what I was gonna say, I lost my train of thought last time you asked a question that I I'd wanna note. We are largely a reseller, but I will note that we have partnerships as well. And people can so if you are a sports team or a venue, you may choose to put tickets directly on sale at StubHub, and you can do that today. You may do that because you know what? I use that tourism example. Hey. You know what? There are people that just go to StubHub because they don't know about the Paramount or the Flynn Theater, right, if they're coming from out of town. So they go to StubHub to see, and those those venues I don't know if those two particularly, but, like, there are other sports teams and venues that list directly, so those aren't resale. We have partnerships as well with Broadway and others that they put that. So I'll note that we are currently largely resale, but it is not uniquely resale. There are cases where, I'll call them rights holders, right, are listing directly on our site as well. So I wouldn't you know, just I just note that we might I wanna say that these are Right. All all I just wouldn't know. We are largely

[Emily Carris Duncan (Member)]: Yeah.

[Michael Marcotte (Chair)]: Yeah. But that's that's But

[David London (StubHub, Government Affairs)]: I just wanna I do wanna note that the industry is changing where, again, just like people are going to kayak and saying, can I compare on multiple sites? The tourism industry is huge. People experiential is becoming huge. People are going on StubHub because they know they're gonna be in x city, and they just wanna know what's there. And teams and venues are recognizing that and so listing direct on our site as well.

[Abbey Duke (Member)]: I get it. That makes sense.

[Michael Boutin (Member)]: Yeah, mean, the disclosure part of it is really important because again, looked again, Book of Mormon, March. I've seen a trend. Yes. In March, it's 135 at the Flynn and I pulled it up here at $656. But I don't know. I know that that ticket is not available on the Flynn, so I'm assuming that was uploaded. Correct?

[David London (StubHub, Government Affairs)]: I have to look at the I I don't want to comment on exact listing. But, yes.

[Michael Boutin (Member)]: I I don't see any

[David London (StubHub, Government Affairs)]: What you're saying is you went back to the primary and said that ticket's unavailable, so you're connecting. Yep.

[Michael Boutin (Member)]: Right. I'm assuming that that's somebody that's reselling their ticket.

[David London (StubHub, Government Affairs)]: Mhmm.

[Michael Boutin (Member)]: I, as a consumer, have no idea that that's the case. And I think to get back to what Abbey was saying, I think that part of it is extremely important because if I knew that this was the equivalent of a scalper at the Right. At a at a venue, I would probably not. No. No. In fact, I just would.

[David London (StubHub, Government Affairs)]: No. No. And

[Michael Marcotte (Chair)]: and so I think what

[David London (StubHub, Government Affairs)]: we would say is fans should have choices. Right? Different but to your point about transparency and that if we can work with you on better disclosures, like but we're happy to have that that conversation.

[Jonathan Cooper (Member)]: So I'm thinking of so what we're talking about is the experience of the person going into the show. But I feel like a lot of what we had sort of taken testimony on to date has been about the venues

[David London (StubHub, Government Affairs)]: themselves

[Jonathan Cooper (Member)]: that found that they were being misrepresented, that their imagery was being used to provide a fig leaf for interceptive practices that made people think, I'm buying a ticket from the Blank Theater in Vermont. I'm looking forward to going out. A lot of the testimony that we had heard referred to people being deceived. And so I understand that there is a market for ticket resale, just as there always has been. And I felt that the goal of our legislation, the focus had been about protecting the venues that are ultimately seeing their reputations being tarnished by people who are upset, and, you know, it's not clear to them that the theater didn't charge you that. You know? But I one of the things that came up as I was looking through this legislation was, as written, it seemed to perhaps prevent any resale from taking place because it has language about affiliated And I'd like to hear, I think at the beginning of testimony, you'd mentioned that seemed overly broad. But what I would like to know is, I wanna make sure that this legislation protects those theaters from these other practices, from reputational harm from people who associating what they're mad about with that theater.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: 100%.

[Jonathan Cooper (Member)]: I'm sort of satisfied that with this particular business, you know that you're not buying a ticket from a theater. This is called StubHub. And so what I did want to know is how we can how this language can get can limit the activity of the people that we don't want doing this to our venues anymore. And that's really who I'm that's the consumer, you might say, that I'm hoping to protect through this legislation. So how do we get your concerns, using this language, assuaged?

[David London (StubHub, Government Affairs)]: Yeah. And we had these exact conversations in Connecticut, and they were able to strike that balance. And the easiest way I can kinda describe it is if you were is is all about the domain name. And by that, I mean, you should not be able to put official Dave Garaby venue officialseller.com. Right? Because that's in the domain name. Right? So you need to you need to protect the usage of that in the domain. What is common practice, not just in ticketing, but generally, is you may go on StubHub. And when you're on that exact page to look at Luke Bryant tickets, it may say subhub.com backslash luke.bryant. That's not deceptive. So what we need to do is make sure we cater it towards the domain name and other fraudulent activity, not say that no one selling tickets absent the venue or the artist can use the venue or artist name. Using the name is not deceptive. Using it, for example, in a domain is where it's deceptive. And I'm happy to provide the the language from Connecticut. I don't wanna speak for them. I believe, like Yeah. Passed under 47 to zero, I also think the attorney general's office weighed in on it as well. And so we think that's just the right balance, to do exactly what you discussed.

[Jonathan Cooper (Member)]: Do you see and and with that in mind, like, one of the things that one of the people giving testimony had shown us a sort of a warren of website names that are just popping up around a show, and it all seems, Nick, something that you would very search engine optimization minded. Does StubHub partner is there a way in which StubHub is assisting states and passing legislation in sort of helping to cure that or prevent those tickets acquired through those websites from

[David London (StubHub, Government Affairs)]: I think we're at nearly a dozen states where we've worked with states to pass what we would call appropriate, good, balanced, deceptive website language. And in a lot of cases, like I use Colorado, right, when the venue StubHub and Colorado Perg are all saying this is the right language, we think that's a good thing.

[Michael Boutin (Member)]: Thank you.

[Kirk White (Ranking Member)]: To carry Jonathan point one step further, a lot of the venues are really concerned because they end up being at the point of glance, the only contact that fraudulent ticket holder has. Now you state that, well, first, identified StubHub, so there's not that conflict. But you state that in your correspondence with somebody who uses your site and buys a ticket that, you know, if you have a problem, call this. Could you share with us some of that kind of communication that you use so we can look at it?

[David London (StubHub, Government Affairs)]: Happy to.

[Kirk White (Ranking Member)]: Yep. And, you know, maybe poke that into something.

[David “Dave” Bosch (Member)]: Thank you.

[David London (StubHub, Government Affairs)]: Yeah. Happy to follow-up with them.

[Edye Graning (Vice Chair)]: So you're primarily a reseller, and the tickets that you list are the tickets that people have put up for sale. Is that correct?

[David London (StubHub, Government Affairs)]: Yes, so 99% of the resellers on our site are fans.

[Edye Graning (Vice Chair)]: But you don't go back and check with the venue to you don't coordinate anyway to find out whether or not these tickets are. Again, that's something we

[David London (StubHub, Government Affairs)]: this is we'd we'd love to be able to verify more, but that when the primary is blocking us from accessing and being able to verify, that's where the challenge becomes. That's the difference between ticketing and what I'll we'll say airlines and hotels.

[Edye Graning (Vice Chair)]: Right? How do you know if, for example, there's only 3% of the tickets available at that venue still available?

[David London (StubHub, Government Affairs)]: No. But we so because you're I I assume you're referencing a listing that says 3% of tickets. I am. Yes. We're we know what's on our site.

[Edye Graning (Vice Chair)]: You're saying only 3% of tickets are left. Are you talking about 3% of tickets that are on your site? Yes. As opposed to 3% of tickets available at the venue? Yep. So do you not I don't know that that would be clear to me. It wasn't clear to me now.

[Michael Boutin (Member)]: So your, for lack of a better analogy, your eBay of tickets out. Yeah. Because when I go on eBay, I know the dealer that's actually selling me the tickets, and there are direct dealers that are selling. I shouldn't say dealer. That doesn't sound

[Michael Marcotte (Chair)]: right.

[David London (StubHub, Government Affairs)]: Yes. But I know what you mean.

[Michael Boutin (Member)]: Yeah. I mean, because when when I go on here, it looks like it's coming from stuff. It's not a third party. Whereas if I go to eBay, it tells me the, you know, the sellers information, what their score of how well they are, you know, all that information. And I'm sure we all have our stories of eBay and how we did get the product. And I'm wondering how you would feel about catering the, not catering, but modifying the legislation to make you, I shouldn't, not make you, but well in Vermont, yeah. So we know this is not coming from you. This is coming from Michael in Vermont, right? Where there's a direct communication because you can email, I think you can email sellers on eBay. I can use email, like, decades. That's not true. Think I did just use it, but.

[David London (StubHub, Government Affairs)]: Yeah. The the so it's the first time I've been asked that question, so let me look into it. What I'd say that we're we're a little bit different is because it's all digital. Right? You aren't you don't have to physically mail and and that sort of thing. Right? We are just passing it through, and we're actually getting you the tickets. The other complicated factor here so Ticketmaster controls 80% of the primary market. They are in a lawsuit with the Department of Justice and 40 AGs, including Vermont, on a number of anticompetitive, practices, including with their safety technology that restricts transfer. What they're saying is we control 80% of the market. We only want you to transfer on Ticketmaster. So which is, again, being litigated at the moment. And I say that because for Ticketmaster tickets, you're actually not even transferring the tickets on StubHub. StubHub is requiring our users to go to Ticketmaster to transfer the tickets because they're blocking us from doing it. The consumer doesn't want that. The seller doesn't want that. And so in that case where it's a Ticketmaster transaction and you're buying the tickets on StubHub, but you're transferring them via Ticketmaster, we actually might not have insight on who that is. So one thing I would just flag to your example, I think on the front end that it's resale, that it's not ours, something like that might be doable. What I don't know if it's as applicable is saying that it is Mike from Montpelier because the transaction might be on Ticketmaster, and they're that's where the track transaction's actually taking place. That's the challenge in this industry.

[Michael Boutin (Member)]: Right. But if you're I mean, I wonder if we could write legislation to prevent that from happening. But, that being said,

[David London (StubHub, Government Affairs)]: we we we welcome that conversation. Not surprisingly, by the way. Can we take questions about that for the next twenty minutes? I'd love to talk about it.

[Michael Boutin (Member)]: I do think that it would be extremely beneficial for people in the state of Vermont to know, or I mean, across The United States to know that this is not you selling it and to be able to actually access the actual deal, sell it and know that it's pretty clear.

[David London (StubHub, Government Affairs)]: And, again, because of the complexities, number of players, let me get back to you on how doable that second part is because, again, in those in those cases where it is a ticket mass transaction, I just wanna make sure that that's feasible.

[Emily Carris Duncan (Member)]: Yeah. Just follow-up on that point, I'm a big crafter, so I buy digital patterns all the time.

[David London (StubHub, Government Affairs)]: Nice.

[Emily Carris Duncan (Member)]: And I would just suggest maybe looking at a place like Ravelry, where they It is a Most people are really viewing it. Physical objects, I don't typically know. They're selling digital patterns. Sometimes they have a feasibility where you can sell it through the actual website and download it there, or you can get it bopped out to somebody's blog or their own website and sell it through there, so there's some flexibility. You're able to kind of As you're building the profiles and the users are able to talk to each other and understand and be verified and that sort of stuff. Also look at something like Etsy, where it's oftentimes dealing with actual physical objects, but also digital, there are potentially models that could allow for that profile building and that trust between sellers and purchasers that step up is meant to be facilitating to beef up that possibility.

[Monique Priestley (Clerk)]: I guess a couple things on the Ticketmaster like, and Live Nation type of stuff and a lawsuit going on and all that kind. We don't have any of those venues in Vermont, so it's it's it's a little bit like

[David London (StubHub, Government Affairs)]: I appreciate that. Yeah. Use that as an example on top of mind, but I fully fully appreciate that.

[Monique Priestley (Clerk)]: Totally. And in a related Ticketmaster does allow the no transfer except for face value to keep from scalping. But relatedly, just I would actually love to Like you're saying Ticketmaster blocks, and I totally respect that, but would love to hear the Vermont venues respond to everything you're saying as far as like in ways they want to

[Emily Carris Duncan (Member)]: make it easy for you to be able to bear. It's like that. Yeah.

[David London (StubHub, Government Affairs)]: Absolutely. And and I use Ticketmaster not surprisingly. It's the behemoth in the industry and fully aware of their oddly lack of presence here here in here in Vermont. One thing I would just note on fan exchanges, that should be an option for fans 100%. And I know a lot of people focus on the lack of increase in ticket prices on fan exchanges. What they also have naturally in fan exchanges is they have a price floor. You can only sell them at that price. So the challenge becomes, and I've done this when I was a legislative staffer in in Massachusetts. Sessions started running late unexpectedly. I had bought those tickets x amount of time before. I realized day of session was gonna be late. I'm not gonna make that event. So I took a $70 ticket, and I sold it for $40 just to try to get my money back. Right? I've done that more recently now. I had a my wife and I were supposed to go to a show. The babysitter canceled two days before. We just got our money back. I didn't wanna sell at face value and compete with everybody at $50.75 dollars. I wanted to list them lower and recoup some of my money back. Fan exchanges don't allow for that. And at times and I again, I appreciate Ticketmaster. Ticketmaster doesn't either. So we what we would just argue is those are good. They should exist. It can't only be that because we also have to allow for tickets to go under that price so that I, as a seller, can recoup some of my money. And as a buyer, I might be able to get a last minute deal. Listen. If you perfect example. You're going to a Red Sox game. The weather looks iffy. You don't wanna make the trek, but someone in Boston's willing to take that last minute deal. They're gonna sell that lower. It's a win win for everybody. So I think the fan exchanges are a good model. They should be an option, but I think people forget about the price floor that inherently exists in that. And that's where we point to a lot of our sales that are under what we'll call face value.

[Herb Olson (Member)]: So do you have some idea, so the cost of the sell? So in other words, your cost of doing business for each ticket. So that would be less, I guess, the event price and less less any market. Guess if I think of what the cost of that resale would be?

[David London (StubHub, Government Affairs)]: The cost of the resale. So it'd be hard to do per ticket transaction. What I'd say is, again, I go back to the fact that we don't have the tickets, so we make zero on the actual sale of the ticket. Right? Our revenue comes from the fees that are attached with that that vary depending on an event. And the the example I use on percentages is percentages can be high or low because there are $5 tickets for for sporting events that a $2 fee is a high percentage. Right? So so that that varies. What I'd say is with all of those fees, what you get is the fan protect guarantee, is the customer service, is the consumer protections that exist at StubHub that don't exist in other places. So it's not I'd have to look to see if we have a per transaction cost fee. But what I'd say broadly is that what those fees go to are things like the customer service where we get endless amount you know, to have the twenty four seven customer service is is a cost. To have the fan protect guarantees is a cost. To make sure that the credit card information that you're sharing that is safe has a cost and preventing you from having those cash exchanges and meeting up with someone on Craigslist is is the you know, this is the safe alternative. So what I'd say is the fee cost goes to the safety we provide. I'd have to look to see if we have a a more specific per transaction what that could be.

[Herb Olson (Member)]: Because I I I understand those are cops doing business. I'm just curious what they are. Yeah.

[David London (StubHub, Government Affairs)]: I don't think you've asked a question, have you? You've been quietly listening and plotting your course.

[Michael Marcotte (Chair)]: Currently, Maine the only jurisdiction in The United States that has any statutes on what we're talking about? The only jurisdiction that is price capping.

[David London (StubHub, Government Affairs)]: The so couple things on that. I believe the only two other stakes that have broad price caps are Kentucky and Rhode Island. And one thing I would note on Maine as well is that there was a recent article in the Portland Press Herald, where the, they they were talking about this bill, and they reached out to the attorney general's office. And the attorney general's office was unsure that this even was a price cap, the way it was drafted. And I don't you know? And so the enforcement of it and if it's real, I think, is I'm basing off that article. So, like, you know so I would just note that it's even a little gray area, in Maine, whether it is based on the AG. I'll also note that the author of the bill filed emergency legislation to try to fix the bill, in this session, that was voted down. I think leadership wants to kinda look at what the bill did. I think it moved quickly. There's clearly a need to revisit it as noted by the emergency legislation. And so I think it's, Kentucky, Rhode Island. I'd have to look at others. And I think Maine is

[Michael Marcotte (Chair)]: in Rhode Island have had their price cap in place.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: I have to look at that.

[Michael Marcotte (Chair)]: Just wondering what their experience

[David London (StubHub, Government Affairs)]: And and some of that and this is a guess on my part, so full disclosure on disclosure. I've learned a lot. Right? I know it's important as we've talked here. You know, a lot of a lot of times, and that's we've seen a lot of states repeal it because these were in place when that, what I'll call, street scalping was prominent and try to curtail that. And when it moved to a regulated safe market, a lot of states repealed it. And I just wonder if Rhode Island and Kentucky haven't, and I don't know if it's being enforced or not. I'd have to look into it. Like, Massachusetts is a perfect example. I think it was a hundred year bill that they repealed in 2024. Right? So there are some of these that in every state, there are kind of bills that have, you know, remain on on the books. I'd have to look if that's the case in Kentucky and Rhode Island.

[Michael Marcotte (Chair)]: Individuals that are purchasing on. Is there a requirement that they're signing that I mean, apparently, you don't have you allow anybody to sell their ticket for whatever amount. So and and I said you can sell as many tickets as you want, as many tickets as you have. As you have. Right. So if

[David London (StubHub, Government Affairs)]: you purchase tickets by bots and So I should note that you legally purchased. Right? So

[Michael Marcotte (Chair)]: So okay. That's what I'm getting at. So when you're when you sign up, are you signing something that says you're doing this legally and you indemnify stuff up in case if you're if you purchase these tickets that you're trying to sell illegally?

[David London (StubHub, Government Affairs)]: Is is it, like, an attestation or something along those lines? I I'm trying to think of the last time. I I believe there is. Let me I I I don't wanna be a bit I wanna make I I believe there is. I just wanna I hate saying things until I see them see them and confirm, but I believe so. Let me circle back with you on that. Are you this So for example, we are it we can be there's ambiguity in Maine. And, we don't we're not the reseller. Right? The the individual is. So in Maine, there is a line when you sell that says, Maine you know, you're attesting that you're following Maine. Like, we have something specific in Maine for Maine law. So I know that exists. I can say that for certainty. I'd have to look at the other provisions off top of my head.

[Michael Marcotte (Chair)]: So I would I would imagine if we pass something, you'd have any sellers in Vermont who would have to follow the law and you would make in in in Rhode Island, you know, what's the experience in Rhode Island, Kentucky, all the all the jurisdictions, I would imagine the closer that all the jurisdictions can come to a mod say a model law

[David “Dave” Bosch (Member)]: Mhmm.

[Michael Marcotte (Chair)]: Easier it is for you and your users to comply with the law.

[David London (StubHub, Government Affairs)]: We're not the only industry where a patchwork can be a challenge, right, as I'm sure you hear in this committee a lot. Yeah. Absolutely. And one thing I'd just note, like, for the Maine law and other laws, it applies to events taking place in that state so that if if someone from Maine purchases in Vermont, they would be subject to that. So the the location of the event is the the Nexus. Right? Because there's there's so many I so I I referenced that that north of 50% of customers that buy from for Vermont events are from out of state. It would hold true for them because even though they're out of state, because they're coming to a Vermont event. It would be different if you were a Vermonter going to a Red Sox game.

[Michael Marcotte (Chair)]: Right. Then it falls under

[David London (StubHub, Government Affairs)]: Or for folks folks northern part of the state that are going to Montreal as well. I know there's places there that are that are closer. Yes. True.

[Michael Marcotte (Chair)]: What challenges have you had in other jurisdictions when they're putting laws like this? I guess and how close are they to what we're talking about?

[David London (StubHub, Government Affairs)]: Yeah. I mean, again, I think, you know, when you look at the deceptive website, it's just it's that broadness that we we talked about. The other you know, outside of the the price cap, that's really the the challenge that that we're seeing here. I mean, I think what I'll I'd I'd say is the edges, right, that we wanna work with you on. I think we can find broad agreement. Again, I've referenced other states that have done it. I think those are the models where, again, taking out price gaps doesn't mean that you are not addressing the problems in ticketing. Let's address the websites that are where fraud is probably much more rampant than on StubHub. Let's address speculative tickets. Let's address bot activity. Let's make sure that fans, when they purchase, are guaranteed refunds. Right? Like, there are things like that that I think that are consumer focused, that are fan forward, that I think there's broad agreement on, and other states have shown that when they rolled up their sleeves and and kinda dug into it. And and that's why I think it's important when I came here to say, listen. We're not here to say, I'm sure there's lot of people that come say, no. No. No. No. No. We've actually seen other models in other states where, rolling up our sleeves is a much better example. And if this committee and this legislature says, you know what? We've talked here a lot about disclosure. That's an area that we wanna dig in a little bit more. Let's look at examples that work, and let's show you things that we've seen that are challenges, things that we've seen that work, and totally respect that you gotta go back to your venues and others that are that's certainly important. What I just also note, the 6,000 users in Vermont of StubHub probably won't be testifying, but they're, you know, they're certainly impacted by this as well.

[Michael Marcotte (Chair)]: I think disclosure is really important. People can buy whatever they want to buy for whatever price, as long as they understand And what they're if they know what the fees are and what you're paying for. You know, I think maybe some disclosure should be this may not be the same base value, pick as price and

[David London (StubHub, Government Affairs)]: Is is that and not to be the I shouldn't be the one asking questions. I I I totally get that. But is that would would that be helpful to the committee to look back at other states and say, what have they done, not done on disclosure or other places that we think works or doesn't work and provide that with you?

[Michael Marcotte (Chair)]: I think we our our our employer has done

[David “Dave” Bosch (Member)]: Okay.

[Michael Marcotte (Chair)]: And looked at other other jurisdiction.

[David “Dave” Bosch (Member)]: Okay.

[Michael Marcotte (Chair)]: But it may be helpful to point out, you know, some of the things that we're talking about of what other jurisdictions did.

[David London (StubHub, Government Affairs)]: Yeah. And, again, I'd I'd point to that Connecticut law. The Connecticut law passed, I think, two days you'll appreciate this. Passed Passed the house, I think, two days before session. The senate was poised to do it when came and things closed, but it was unanimous in the house. I think that's gonna come right back and get done. And that was you know, there were multiple ticketing bills. They looked at that hard. They Yeah. Removed price gaps. They tweaked the deceptive website language and got to a good place. I think that's probably a good and it's, I think, regionally relative relevant to you. I think that's a good model, and we can certainly provide others that we think make a lot of sense. And, again, Colorado would be a

[Michael Marcotte (Chair)]: good example of that too. You know, like

[David London (StubHub, Government Affairs)]: With respect, I know you don't like the color sorry. I know you don't like the Colorado model, but

[Jonathan Cooper (Member)]: Oh, no.

[Emily Carris Duncan (Member)]: It is. Yes. Yes.

[David London (StubHub, Government Affairs)]: And We're happy to look at Washington State of Oregon or other places that may make more sense.

[Michael Marcotte (Chair)]: I think a couple of things that were brought up here, looking at your site you know, on a particular concert or whatever, it's only, you know, 50 tickets left. I think you're able to make it plainer that it's only 50 tickets left on our site. Because that's that can be a little deceptive. You you're thinking that there's no more tickets out there at all. I think that's important. And when when you check out, is there a list of

[David London (StubHub, Government Affairs)]: here's what the ticket cost. Here's what I'm selling my ticket for. Here's what the tax was. Here's what the fees are. So the way it works is when you see the price on the front end, that's the total price you pay. And then when you get to when you go through the the the process of, you know, click, click, click, click, click, it shows you the total price, and there's an icon there that you hover over, and it lists out the, fees. The way the reason we do it that way, and interestingly enough, the FTC looked at this, and they looked at itemization, what we call itemization, listing it out. What they found was they didn't require it because sometimes more information is more confusing for consumers. So they just said, just list the total price. That's what they care about. We add that icon so you can kinda see.

[Michael Marcotte (Chair)]: I think it's important for people to know what extras they're paid, what's being charged for, what other fees they are involved within that.

[David London (StubHub, Government Affairs)]: No. We have and and, you know, it's interesting because in 2014, we we tried all in pricing and putting it up front because we thought that's what consumers wanted. And what we saw was our you know, we had we had a hit in our because other companies were not doing it. Right? And so fans were so you know, they saw a $70 ticket. They saw ours at 80. They went to the 70. They got charged 90 at the end, and they weren't going back to our site. So we actually had to stop doing all in pricing because the consumer was confused, so we long advocated for having that across the board. I'll just note right now that's an FTC rule. It's not statute. Taking that FTC rule, putting into state statutes, we think are a good thing to to solidify that.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Think

[Michael Marcotte (Chair)]: we're at noon. After lunch. So thank you. Sorry we didn't get to you. It's fine. I I'm here on behalf of the entire entity, which says that's why I so CEQ and others as well. I think we will provide more information to the community as would be helpful. So that is one slice of a very large

[David “Dave” Bosch (Member)]: Okay.

[Michael Marcotte (Chair)]: David, thank you for joining us today. We'll keep working. If you're available, we'll be working through Chris and invite you back again for comments.

[David London (StubHub, Government Affairs)]: I'm in New Englander. I'll come back to New England even on a cold February morning. I'm happy to do it.

[Michael Marcotte (Chair)]: Very good. And Brian, same thing. If you wanna testify as we go down the road, then you're welcome to come in. Sure.

[David London (StubHub, Government Affairs)]: And I hope I answered all your your questions best I could. Happy to follow-up, provide some additional details Yeah. And get you specific. So happy. I took some I took some notes. They're probably not perfect. I'll work with our our folks here and all of you to to get you what you need.

[Michael Marcotte (Chair)]: Yeah. That'd be great. Thank you. Appreciate it. Thank you.

[David Hall, Director, Business Services Division, Vermont Secretary of State’s Office]: Enjoy lunch.

[Michael Marcotte (Chair)]: Back here at 01:00 to have a walk

[Emily Carris Duncan (Member)]: through