HIGHLIGHTS:

• The Ticket Sale Website agreed to a $10 million settlement for misrepresenting ticket prices by failing to provide all-in pricing disclosure at the beginning of the transaction.
• The FTC’s current leadership has identified this type of deceptive pricing practice as one of its top enforcement priorities.
• This settlement followed a letter the FTC sent to the Ticket Sale Website warning of noncompliance with the Fees Rule. The FTC has recently issued similar warning letters to 13 property management software providers and 97 auto dealerships. In each case, the FTC’s warning letters have focused on potential deception of consumers by failing to provide all-in pricing disclosures. The FTC is also attempting to extend its express UDAP authority to more industries, most notably to housing rentals, with a potential new rule on unfair and deceptive rental housing fees in the early stages of the rulemaking process.

CASE SUMMARY:

In May 2025, the Federal Trade Commission’s Rule on Unfair and Deceptive Fees (the “Fees Rule”) took effect. The Rule prohibits hidden fees in the live-event ticketing and short-term lodging industries under the theory that hiding fees during the checkout process is an unfair and deceptive practice. The Rule followed a March Executive Order on Combating Unfair Practices in the Live Entertainment Market, which required price transparency at all stages of the live-event ticket-purchase process.

Shortly after the Fees Rule took effect, the FTC issued a letter to the country’s largest ticket resale platform (the “Ticket Sale Website”) warning that it was in violation of the Fees Rule. Shortly thereafter, the FTC filed a complaint in the U.S. District Court for the Southern District of New York alleging violations of both the FTC Act (for alleged misrepresentation of the total price of a good or service) and the new Fees Rule (for allegedly not displaying the total price at all stages of the ticketing process). The Complaint alleged that the Ticket Sale Website intentionally delayed full compliance with the Fees Rule to gain an unfair competitive advantage in sales of highly-sought-after tickets to particular sporting events.

On April 9, 2026, the FTC announced a settlement in which the company neither admitted nor denied the FTC’s allegations, but agreed to pay $10 million to a consumer fund to provide redress to any harmed consumers. The settlement also prohibits the Company from: (1) offering, displaying, or advertising any price of a good or service without clearly and conspicuously disclosing the total price; (2) failing to disclose the total price more prominently than any other pricing information; (3) failing to clearly and conspicuously disclose the amount of any fees or charges that have been excluded from the total price and what they are for, as well as the final payment amount—before the consumer agrees to pay for a product or service; and (4) further violating the Fees Rule.

RESOURCES:
You can review all of the relevant court filings and press releases at the FTC’s Enforcement page.

• Rule on Unfair and Deceptive Fees
• Executive Order on Ticketing
• Warning Letter
• Proposed Order
• Complaint

Enforcement Alerts by Hudson Cook, LLP, written by the attorneys in the firm’s Government Investigations, Examinations and Enforcement and Litigation practice groups, are provided to keep you informed of federal and state government enforcement actions and related actions that may affect your business. Please contact our attorneys if you have any questions regarding this Alert. You may also view articles, register for an upcoming CFS Bites monthly webinar or request a past webinar recording on our website.