AXS Vs Internet Referral Services - DOC001

Case 2:24-cv-00377-SPG-E Document 1 Filed 01/16/24 Page 1 of 46 Page ID #:1
1 DORSEY & WHITNEY LLP

J. Michael Keyes (SBN 262281)
2 [email protected]
Connor J. Hansen (pro hac vice)
3 [email protected]
701 Fifth Avenue, Suite 6100
4 Seattle, WA 98104
Telephone: 206.903.8800
5 Facsimile: 206.903.8820
6 DORSEY & WHITNEY LLP
Kent J. Schmidt (SBN 195969)
7 [email protected]
600 Anton Boulevard, Suite 200
8 Costa Mesa, CA 92626
Telephone: 714.800.1400
9 Facsimile: 714.800.1499
10 Attorneys for Plaintiff AXS Group LLC
11
UNITED STATES DISTRICT COURT
12
CENTRAL DISTRICT OF CALIFORNIA
13
Case No. 2:24-CV-00377 REDACTED
14 AXS GROUP LLC,
VERIFIED COMPLAINT FOR:
15 Plaintiff,
1) FEDERAL COPYRIGHT
16 v. INFRINGEMENT;
17 INTERNET REFERRAL SERVICES, 2) VIOLATION OF DIGITAL
LLC, EVENT TICKETS CENTER, MILLENNIUM COPYRIGHT
18 INC., VERIFIED-TICKET.COM, ACT;
AMOSA.APP and SECURE.TICKETS, 3) TRADEMARK
19 COUNTERFEITING;
Defendants. 4) FEDERAL TRADEMARK
20 INFRINGEMENT;
21 5) FEDERAL FALSE
DESIGNATION OF ORIGIN
22 AND UNFAIR COMPETITION;
23 6) UNFAIR COMPETITION
UNDER CAL. BUS. & PROF.
24 CODE;
7) COMMON LAW FALSE
25 DESIGNATION OF ORIGIN
AND UNFAIR COMPETITION;
26 8) CIVIL CONSPIRACY; AND
27 9) BREACH OF CONTRACT.
28 JURY DEMANDED
1 Plaintiff AXS Group LLC by and through its counsel, Dorsey & Whitney LLP,
2 for its Verified Complaint alleges as follows:
3 I. INTRODUCTION & SUMMARY OF RELIEF REQUESTED
4 1. AXS Group LLC (“AXS,” pronounced “Access”) brings this action
5 against Defendants Internet Referral Services LLC, Event Tickets Center, Inc.,
6 Verified-Ticket.com, Amosa.app and Secure.Tickets alleging numerous federal and
7 state claims related to copyright infringement, violations of the Digital Millennium
8 Copyright Act, trademark counterfeiting, trademark infringement, unfair
9 competition, unfair or deceptive trade practices, and civil conspiracy arising from
10 Defendants’ willful, deliberate, and malicious acts that are causing substantial and
11 irreparable harm to AXS’s goodwill, reputation, and business. Defendants’ acts are
12 also causing widespread damage and harm to unwitting consumers who are the
13 victims of Defendants’ fraudulent conduct.
14 2. AXS provides proprietary ticketing software and services including
15 through an internet website and mobile application (the “AXS Platform”) to hundreds
16 of event organizer clients who present sports and entertainment events in the United
17 States, including the Crypto.com Arena in Los Angeles, the T-Mobile Arena in Las
18 Vegas, Nevada, and the Ryman Auditorium and Grand Ol Opry in Nashville,
19 Tennessee. AXS utilizes the AXS Platform to market, sell and distribute tickets on
20 behalf of its event organizer clients, and delivers digital tickets to end user customers
21 who purchased tickets on the AXS Platform using AXS’s patented AXS Mobile ID
22 technology.
23 3. The original sales process, where the tickets to an event are sold to the
24 public on behalf of event organizers for the first time, is sometimes known as the
25 “primary market” sale of tickets. After a ticket has been sold on the primary market,
26 the purchaser of such ticket, who for the most popular events where the highest resale
27 prices are commanded, is often a professional reseller or broker making a large profit
28 on the resale of the ticket, will list the ticket for sale on a website that offers the ticket
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VERIFIED COMPLAINT Case No. 2:24-CV-00377
1 for resale or what is sometimes known as the “secondary market” sale of tickets.
2 4. AXS sells “primary market” tickets on behalf of its clients and also
3 provides a “secondary market” service for persons who purchased an AXS client
4 event ticket in the primary market to post their ticket for resale using a feature of the
5 AXS Platform (known as “AXS Official Resale”), where new end user buyers can
6 purchase the ticket and AXS will fulfill the delivery of the ticket using AXS Mobile
7 ID technology.
8 5. AXS does not own any of the tickets that it sells. Rather, in the primary
9 market, AXS acts in an agency capacity for its clients—the venues, promoters, and
10 teams on whose behalf AXS sells live event tickets to their fans. In the secondary
11 (resale) market, AXS offers the sales platform and ticket delivery for resellers to sell
12 their tickets to new buyers on the AXS Official Resale marketplace. AXS’s goal is
13 to serve its clients by getting authentic tickets into the hands of their fans on the terms
14 established by those clients, and to serve fans by providing them access to buy tickets
15 for the events they want to attend.
16 6. As detailed herein, the tickets purchased through the AXS Platform are
17 branded with Plaintiff’s trademarks. Plaintiff owns a valid and subsisting copyright
18 in the mobile application (the “AXS App”) that allows users to buy, sell, view, and
19 use their digital tickets. Further, as set forth below, in order to prevent fraudulent
20 activity, Plaintiff has developed proprietary security features to ensure that AXS
21 digital tickets are associated with the consumers who purchased them and ensure that
22 consumer data is protected.
23 7. Defendants operate third-party ticket retail platforms and/or ticket
24 delivery services, listing, selling and delivering secondary market tickets listed by
25 ticket resellers or brokers on third party secondary market ticket sales websites.
26 Collectively, and on information and belief, Defendants market, advertise, sell,
27 display, distribute, and/or deliver to consumers digital tickets that purport to be
28 authentic AXS digital tickets. In reality though, the digital tickets, made to look like
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1 AXS tickets, distributed by Defendants through unaffiliated websites or emails are

2 counterfeits. These counterfeit tickets bear Plaintiff’s trademarks and, on information
3 and belief, were created, in whole or in part by one or more of the Defendants illicitly
4 accessing and then mimicking, emulating, or copying tickets from the AXS Platform
5 and/or the AXS App, without Plaintiff’s permission or consent. Further, at least two
6 of the Defendants (Internet Referral Services LLC and Event Tickets Center, Inc.)
7 have also represented to consumers that they are using AXS’s proprietary technology
8 to sell, resell, deliver, or transfer tickets, when they are in fact circumventing AXS’s
9 technology. Defendants operate in the shadows of the internet. In some instances,
10 Defendants have gone to great lengths to conceal their identities.
11 8. This pernicious and illicit activity is causing disruption to Plaintiff’s
12 business and negatively impacting its goodwill and reputation in the marketplace as
13 well as harming and disrupting the business of AXS’s clients. Consumers who
14 purchase or are sent these counterfeit AXS tickets do not know the tickets of the
15 delivery method are fake. These consumers do not know that the ticket and delivery
16 method is not actually associated with AXS because both the ticket and the delivery
17 method look like real AXS tickets or the real AXS App. Consumers who receive
18 these fake tickets unwittingly arrive at the venue, present what they think are
19 authentic tickets from the venue’s official ticketing provider (i.e., AXS) and may be
20 turned away or otherwise denied admission. These aggrieved consumers, in turn,
21 believe Plaintiff is the cause of the problem when, in reality, Defendants are the
22 culprits behind these brazen and blatantly illegal acts.
23 9. Defendants’ continued unauthorized use of Plaintiff’s trademarks and
24 protected elements of Plaintiff’s copyright protected work inflicts damage and injury
25 to AXS’s goodwill, reputation, and business and has and will continue to cause
26 widespread, irreparable injury unless enjoined by this Court. Plaintiff seeks
27 expedited discovery, immediate injunctive relief, all monetary damages available to
28 it in law or in equity, and an award of attorneys’ fees and costs for Defendants’
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1 wanton and oppressive conduct.

2 II. PARTIES
3 10. AXS is a limited liability company organized under the laws of the state
4 of Delaware and has its principal place of business in this judicial district at 425 W.
5 11th Street, Los Angeles, CA 90015, United States.
6 11. Defendant Internet Referral Services LLC (“IRS”) is a foreign limited
7 liability company organized under the laws of the state of Delaware. IRS can be
8 served with process by serving its registered agent Harvard Business Services, Inc.
9 at 16192 Coastal HWY, Lewes, DE 19958. As described in more detail below,
10 Defendant IRS owns and operates a ticket retail service called Tickets-Center.com.
11 On information and belief, IRS owns and operates additional ticket retail platforms,
12 the identities of which are unknown to Plaintiff.
13 12. Defendant Event Tickets Center, Inc. (“ETC”) is a corporation
14 organized under the laws of the State of Florida with its principal address at 308 West
15 University Avenue, Suite B, Gainesville, FL 32601. As described further below,
16 Defendant ETC operates a digital ticket retail and/or delivery service through the
17 domain name eventticketscenter.com. On information and belief, ETC may own
18 and/or operate additional ticket retail platforms, the identities of which are unknown
19 to Plaintiff.
20 13. Defendant Verified-Ticket.com operates a digital ticket retail and/or
21 delivery service through the domain name verified-ticket.com. Attached hereto as
22 Exhibit A is a copy of the “Whois”1 report for Defendant Verified-Ticket.com. As
23 set forth therein, Google LLC acted as the domain name registrar for Defendant
24
1
25 Whois is “a domain lookup [that] allows you to trace the ownership and tenure of
a domain name” and its reports contain “details such as the registration date of the
26
domain name, when it expires, ownership and contact information, nameserver
27 information of the domain, the registrar via which the domain was purchased, etc.”
See WHOIS, Frequently Asked Questions, https://www.whois.com/whois/ (last
28
accessed June 30, 2023).
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1 Verified-Ticket.com and the contact information provided is a proxy called “Contact

2 Privacy Inc. Customer 7151571251.” Contact Privacy Inc.’s Terms of Service
3 provide that the Customer number is “an individual customer identification number
4 which is unique per domain name.” 2 Accordingly, on information and belief,
5 Customer 7151571251 is the individual or entity who owns and operates verified-
6 ticket.com, however the true identity of the individual or entity behind this proxy is
7 unknown to Plaintiff at this time.
8 14. Defendant Amosa.app operates a digital ticket retail and/or delivery
9 service through the domain name amosa.app. Attached hereto as Exhibit B is a copy
10 of the Whois report for Defendant Amosa.app. As shown in that Whois report,
11 Dynadot LLC acted as the registrar for Defendant Amosa.app and the contact
12 information provided therein is “Redacted for Privacy.” The true identity of the
13 individual or entity who owns and operates Defendant Amosa.app is unknown to
14 Plaintiff at this time.
15 15. Defendant Secure.Tickets operates a digital ticket retail and/or delivery
16 service through the domain name secure.tickets. Attached hereto as Exhibit C is a
17 copy of the International Corporation for Assigned Names and Numbers report for
18 Defendant Secure.Tickets. As shown in the ICANN report, Namecheap Inc. acted as
19 the registrar for Defendant Secure.Tickets and the contact information provided
20 therein is “Redacted for Privacy.” The true identity of the individual or entity who
21 owns and operates Defendant Secure.Tickets is unknown to Plaintiff at this time.
22 16. Plaintiff intends to seek discovery, including on an expedited basis
23 and/or through subpoenas to third-party registrars, to ascertain the true identities of
24 the individuals or entities associated with the Defendants Verified-Ticket.com,
25 Amosa.app, and Secure.Tickets. Plaintiff will either file an amended complaint
26
2
27 Contact Privacy Inc. Terms of Service, https://contactprivacy.com/?action=wp_
mailer_show_terms#:~:text=We%20shall%20have%20the%20right,in%20the%20g
28
ood%20faith%20belief (last accessed Aug. 4, 2023).
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1 and/or seek leave of this Court to do so when their identities are ascertained.
2 III. JURISDICTION AND VENUE
3 17. This Court has subject matter jurisdiction over this case pursuant to
4 28 U.S.C. § 1331 and § 1338 because this dispute concerns the rights of parties under
5 the Copyright Act, 17 U.S.C. § 101 et seq., and the Lanham Act, 15 U.S.C. § 1051 et
6 seq.
7 18. This Court has supplemental jurisdiction over all state claims under 28
8 U.S.C. § 1367 because all state law claims asserted herein are related to the same
9 controversy, specifically Defendants marketing, offering for sale, and sale of
10 counterfeit tickets, which give rise to the federal causes of action.
11 19. This Court has personal jurisdiction over Defendants because, upon
12 information and belief, Defendants regularly: (a) conduct, transact, and/or solicit
13 business in California and in this judicial district; (b) derive substantial revenue from
14 their business transactions in California and in this judicial district; and/or otherwise
15 (c) avail themselves of the privileges and protections of the State of California such
16 that this Court’s assertion of jurisdiction does not offend traditional notions of fair
17 play and due process. For example, as set forth in more detail below, one or more of
18 the Defendants have offered for sale, sold, distributed, displayed and/or allowed to
19 be displayed counterfeit tickets to consumers in this judicial district, including fake
20 or fraudulent digital tickets to games for the LA Clippers and LA Kings. In addition,
21 Defendants’ infringing conduct has caused injury to Plaintiff in California and this
22 judicial district such that Defendants should reasonably expect such actions to have
23 consequences in California and this judicial district.
24 20. Further, on information and belief, one or more of the Defendants have
25 downloaded the AXS App for purposes of reverse-engineering it and otherwise
26 violating the Copyright Act as detailed and set forth herein. When using or
27 downloading the AXS App, users agree to and are bound by AXS’s Terms of Use,
28 which provide: “you agree that any action at law or in equity arising out of or relating
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1 to these Terms shall be filed only in the state or federal courts located in Los Angeles
2 County, California, and you hereby consent and submit to the personal jurisdiction
3 of such courts for the purposes of litigating any such action.” Accordingly,
4 Defendants have consented to personal jurisdiction in this judicial district.
5 21. Alternatively, this Court has personal jurisdiction over any foreign
6 Defendants pursuant to Rule 4(k)(2) of the Federal Rules of Civil Procedure to the
7 extent any given Defendant is not subject to the jurisdiction of any state’s court of
8 general jurisdiction, because exercising jurisdiction over Defendants, who conduct
9 substantial business with consumers in the United States, is consistent with the
10 United States Constitution and its laws.
11 22. Venue is proper in this judicial district pursuant to 28 U.S.C.
12 § 1391(b)(2) and § 1400 because, as described herein, Defendants conduct, transact,
13 and/or solicit business in this judicial district and the actions that give rise to the
14 allegations of this Complaint, namely Defendants’ marketing, offering for sale, and
15 sale of tickets to consumers occur in this district. Defendants are also subject to
16 Plaintiff’s Terms of Use, as noted above, which require any lawsuit to be brought in
17 the state or federal courts in Los Angeles.
18 IV. PLAINTIFF’S E-TICKETING BUSINESS OPERATION
19 The AXS Platform for Selling and Re-Selling Tickets
20 23. The AXS Platform includes an online website (https://www.axs.com)
21 and the AXS App, which interoperates with the AXS website to provide ticket sale
22 and distribution for sports and entertainment events. The AXS App is available for
23 download from both the Apple App Store (for Apple devices) and Google Play Store
24 (for Android devices). In the Apple App Store, the AXS App has an average rating
25 of 4.7 out of 5 stars, with nearly 267,000 ratings as of the time this Complaint was
26 filed. In the Google Play Store, the AXS App enjoys a 4.3 star rating, has nearly
27 20,000 reviews, and has been downloaded more than 5,000,000 times. In total, the
28 AXS App has been downloaded by users. Consumers can
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1 search for and purchase primary market and resale tickets to various AXS client
2 events through the AXS Platform, both online and in the AXS App.
3 24. AXS uses security and access control measures to prevent misuse of the
4 AXS App, including
5 .
6 25. Plaintiff has more than 300 event organizer clients and sells millions of
7 tickets for thousands of events per year in the United Sates. AXS assures consumers
8 that AXS tickets purchased through the AXS Platform, whether a primary sale or a
9 secondary sale ticket, are “100% authentic tickets.”
10 26. When a ticket is sold again from the buyer of that ticket to a new buyer,
11 it is sometimes known as a “resale” or a “secondary market” ticket. In the primary
12 market, the venue, team, or event promoter sets the price for the ticket. In the resale
13 market, ticket prices are set by the ticket reseller (also referred to as a “broker”). If
14 a reseller or broker sells a genuine AXS ticket through AXS Official Resale, that
15 resold ticket will be delivered through the AXS Platform directly to the purchaser in
16 their AXS App. In order to access that resold ticket, the purchaser will have to
17 download the AXS App on a mobile device so that the authentic AXS ticket can be
18 delivered. AXS assures consumers that resale tickets purchased through the AXS
19 Platform are “100% authentic tickets.”
20 27. Depending on the client, event, or venue, some tickets sold through the
21 AXS platform include “premium” benefits such as access to enhanced seating or
22 “VIP packages” that may include additional perks such as special merchandise,
23 access to “meet-and-greets” with celebrities, and other benefits. The benefits are then
24 associated with the authentic AXS ticket and will render in the customer’s AXS App.
25 If a ticket has been counterfeited, mimicked, or emulated, as is the case with the
26 tickets marketed by Defendants, the premium benefits may not render in the
27 customer’s AXS App, thus denying the customer the benefits that they purchased.
28
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1 AXS Mobile ID Technology (Formerly Known as “Flash

2 Seats”)
28. Regardless of whether consumers purchase original issue primary
3
market tickets from AXS, or resale market tickets through AXS Official Resale, AXS
4
ensures they are “100% authentic” because of proprietary software developed by
5
AXS called “AXS Mobile ID.” AXS Mobile ID is an identity-based ticketing
6
technology that assigns a unique identifier to each consumer and a mechanism for
7
associating each digital ticket to the proper consumer. For security purposes, AXS
8
developed a proprietary code-rotation algorithm, which changes the “QR code”3 on
9
an AXS Mobile ID digital ticket on a variable duration, typically set to every 59
10
seconds. The term “AXS Mobile ID” is prominently displayed on Plaintiff’s website
11
and other locations and is often times accompanied by explanatory text about how
12
AXS Mobile ID provides a “secure ticketing experience for fans.”
13
29. Regardless of whether a consumer purchases a primary or resale market
14
AXS digital ticket, the ticket will always be delivered to the purchaser inside the AXS
15
App on the purchaser’s mobile device. The purchaser then presents the digital ticket
16
inside the AXS App at the venue to gain admission.
17
30. AXS uses a distinctive and recognizable color scheme and layout for its
18
digital tickets in the AXS App. There is an ability for the customer to select from a
19
few color schemes and likewise newer AXS App versions have modified layouts, but
20
genuine AXS tickets always have small AXS digital watermarks throughout the
21
background and prominently display the term AXS Mobile ID. There is also a
22
rotating QR code generated from within the AXS App, along with information about
23
the venue, event, and purchaser contained on the face of the digital ticket. The default
24
and most common color scheme contains a deep, rich purple hue background. The
25
26 3
A QR Code is a “two-dimensional barcode printed as a square pattern of black and
27 white squares that encodes data.” QR Code, Merriam-Webster,
https://www.merriam-webster.com/dictionary/QR%20code (last accessed June 30,
28
2023).
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1 following is an example of how a typical AXS digital ticket appears within the AXS
2 App:
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20 31. Since at least September 1, 2020, Plaintiff has promoted AXS Mobile
21 ID to customers and prospective customers to assure them that both the sale and
22 purchase of AXS digital tickets is safe and secure. These assurances about AXS
23 Mobile ID are prominently displayed and promoted to consumers and fans. They
24 can be found on multiple locations on AXS’s website, on the Apple App and Google
25 Play stores, and several Youtube.com videos. Attached hereto as Exhibit D are true
26 and correct examples of how AXS Mobile ID is promoted to the public.
27 32. Further, many of AXS’s client websites that operate entertainment
28 venues and professional sports associations in the Los Angeles area and beyond also
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1 tout the safety and security of using AXS Mobile ID. These include, but are not
2 limited to, Crypto.com Arena, the National Hockey League, The Regency Ballroom
3 in San Francisco, and T-Mobile Arena in Las Vegas. Attached hereto as Exhibit E
4 are true and correct copies of website printouts from these organizations where they
5 promote the safety and security of AXS Mobile ID.
6 33. Prior to adopting “AXS Mobile ID,” AXS had previously used the
7 trademark “Flash Seats” (dating back to at least April 2006) as the name for the
8 electronic delivery of authentic AXS tickets to consumers. References to “Flash
9 Seats” are still made on axs.com, as well as third-party sites that state things such as
10 “AXS Mobile ID (formerly Flash Seats).” Attached hereto as Exhibit F are true and
11 correct copies of references to AXS’s “Flash Seats.”
12 34. To date, AXS (and its clients) have sold millions of AXS-branded
13 genuine electronic tickets to consumers and other purchasers in the U.S. In 2022
14 alone, AXS generated revenues
15 .
16 35. Importantly, genuine AXS digital tickets using AXS Mobile ID are not
17 delivered to a purchaser’s email account. Further, genuine AXS digital tickets are
18 not delivered to any sort of website where purchasers are required to log in and show
19 their digital ticket to gain admission. As detailed herein, the counterfeit digital tickets
20 at the center of this dispute are being delivered directly to purchasers’ email accounts,
21 or through a website unaffiliated with AXS—telltale signs that the consumers have
22 purchased counterfeit tickets.
23 V. PLAINTIFF’S VALID AND SUBSISTING INTELLECTUAL
PROPERTY RIGHTS
24
The AXS Trademarks
25
36. Plaintiff has used the name “AXS” since at least as early as August 2011
26
to offer its goods and services in commerce to consumers in the United States.
27
37. Plaintiff markets its goods and services through its own website, through
28
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1 the AXS App, through its clients, the venue, team and event promoters whose tickets
2 AXS makes available via the AXS Platform, through various social media platforms,
3 and through other print and electronic media.
4 38. Plaintiff and its services have also been featured in prominent, national
5 publications, including but not limited to The Los Angeles Times, The New York
6 Times, Business Wire, Variety, and Billboard. Examples of just some of the articles
7 from these organizations are attached hereto as Exhibit G.
8 39. Through its extensive marketing and exclusive use of the AXS brand,
9 Plaintiff has developed tremendous goodwill associated with it, and consumers have
10 come to associate the AXS brand exclusively with Plaintiff.
11 40. Plaintiff has made significant investments in developing and protecting
12 the AXS brand. Plaintiff owns the following U.S. trademark registrations
13 (hereinafter “AXS Registrations”), all of which have been duly registered with the
14 United States Patent and Trademark Office (“USPTO):
15 Reg. No. Trademark Goods/Services
16 4,429,044 AXS 35: Promotion of sporting events, musical concerts
and other entertainment events of others
17
41: Arranging for ticket reservations for sporting
18 events, musical concerts and other entertainment
events; Ticket agency services for sporting events,
19
musical concerts and other entertainment events,
20 rendered online, through phone orders and through
ticket outlets
21
4,830,497 AXS 9: Computer software for building customer lists
22 ADVANTAGE and marketing campaigns related to entertainment
and sporting events
23
5,880,643 AXS 41: Arranging for ticket reservations for sporting
24 ANYWHERE events, musical concerts and other entertainment
25 events; Ticket agency services for sporting events,
musical concerts and other entertainment events,
26 rendered online, through phone orders and through
27 ticket outlets in various channels of distribution
28
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1 5,954,081 AXS 35: Business research and data analysis services in

2 INTELLIGENCE the field of ticketing for live sports and music
events
3 5,953,686 AXS INSIGHT 35: Business research and data analysis services in
4 the field of ticketing for live sports and music
events
5 5,680,286 AXS PATIO 9: Audio and video recordings featuring recorded
6 SESSIONS musical performances provided through internet,
video-on-demand, digital media and other forms of
7 transmission media
8 41: Entertainment services in the nature of a live
performances, provided live and through internet,
9 video-on-demand, digital media and other forms of
10 transmission media; providing online information
in the field of entertainment concerning
11 performances by musicians and bands; providing a
12 website featuring non-downloadable audio
recordings in the field of musical performances
13 provided through internet, video-on-demand,
14 digital media and other forms of transmission
media
15
41. Each of the AXS Registrations is valid, subsisting, and in full force and
16
effect. True and correct copies of the AXS Registrations are attached hereto as
17
Exhibit H. Further, Registration No. 4,429,044 and Registration No. 4,830,497 are
18
“incontestable” because Plaintiff has used them continuously for at least five
19
consecutive years and the USPTO has acknowledged the declarations of
20
incontestability for these registrations. Plaintiff owns each of the AXS Registrations4
21
and enjoys common law rights with respect to the marks set forth in those AXS
22
Registrations as well.
23
42. Additionally, Plaintiff also owns common law trademark rights with
24
respect to “AXS Mobile ID” for its proprietary software components that ensure
25
consumers that they are using safe and secure AXS technology to buy and sell their
26
digital tickets. Prior to adopting AXS Mobile ID, AXS used the term “Flash Seats”
27
28 4
Plaintiff owns Registration No. 4,429,044 by assignment.
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1 as the name for its proprietary components that ensured consumers they are using
2 safe and secure AXS technology to buy and sell their tickets. AXS also owns
3 common law trademark rights in “Flash Seats.” On March 4, 2021, AXS applied to
4 register with the USPTO the mark “Flash Seats” for, among other services,
5 “[p]roviding temporary use of on-line non-downloadable software for use in the
6 sports and entertainment industries, namely, software for use in the issuance, printing
7 and exchange of event tickets.” Attached hereto as Exhibit I is a true and correct
8 copy of the Notice of Allowance issued by the USPTO on September 28, 2021. Both
9 AXS Mobile ID and Flash Seats have been used in commerce by Plaintiff long before
10 Defendants started their illicit marketing and infringement regimes.
11 43. The marks as reflected in the AXS Registrations, and the common law
12 rights to the marks reflected in the AXS Registrations and to the marks “AXS Mobile
13 ID” and “Flash Seats,” are all collectively referred to herein as the “AXS Marks.”
14 The AXS Copyrights
15 44. Plaintiff also owns copyright registrations covering the AXS App. The
16 copyright registrations cover both the iOS version of the AXS App available on the
17 Apple App Store and the Android version of the AXS App available on the Google
18 Play Store.
19 45. The United States Copyright Office registered Plaintiff’s copyright in
20 “AXS Mobile Application for iOS, Version 5.8.7” under Number TX0009296416,
21 with an effective registration date of July 26, 2023. A true and correct copy of the
22 Certificate of Registration is attached hereto as Exhibit J.
23 46. The United States Copyright Office registered Plaintiff’s copyright in
24 “AXS Mobile Application for Android, Version 5.8.7” under Number
25 TX0009300435, with an effective registration date of August 15, 2023. A true and
26 correct copy of the Certificate of Registration is attached hereto as Exhibit K.
27 47. The Certificates of Registration are prima facie evidence of the validity
28 of Plaintiff’s copyrights in the AXS App. The copyrighted works as reflected in the
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1 Certificates of Registration are collectively referred to herein as the “AXS App

2 Copyrights.”
3 48. By operation of law, the Copyright Registrations cover Plaintiff’s source
4 code embodied in the AXS App, both the iOS and Android versions, as well the user
5 interface of the AXS App and all copyrightable content on the screen displays
6 generated by the source code, including the arrangement and selection of the digital
7 tickets.
8 Notice of Plaintiff’s Trademarks and Copyrights
9 49. Plaintiff provides notice of its trademarks and copyrights rights to
10 consumers and individuals or entities who use Plaintiff’s AXS Platform. For
11 example, on its website, axs.com, and the AXS App, Plaintiff’s Terms of Use
12 provides the following notice relating to Plaintiff’s trademark and copyrights:
13 We are the owner or licensee of all of the content contained on the
Services (which includes, without limitation, all graphics, text, images,
14
photographs, videos, illustrations, and the design, selection and
15 arrangement thereof), as well as the software (including any images or
files incorporated in or generated by the software), underlying code, and
16
data accompanying the software for the Site (collectively, the
17 “Software”). The Services and Software are protected by copyright,
patent and/or trademark and/or other proprietary intellectual property
18
rights, which are owned or licensed by us, and are protected under
19 United States and international intellectual property laws. By using the
Services, you acknowledge that you do not acquire any ownership rights
20
to the Services, Software or any contents thereof.
21
AXS Terms of Use, Ownership, https://www.axs.com/about-terms-of-
22
use_US_v1.html (Dec. 14, 2018) (last accessed November 6, 2023).
23
50. Plaintiff’s Terms of Use also include limits or prohibitions on using
24
Plaintiff’s copyright protected materials, including the AXS App in particular:
25
Our Mobile App is protected by copyright and may not be sold,
26 redistributed, copied, made available to the public, or part of a derivative
work created by you without the express written consent of AXS. You
27 may not attempt to decompile, reverse engineer, disassemble or
otherwise modify our Mobile App, or in any way compromise the
28 security of data stored or transmitted by our Mobile App.
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1 AXS Terms of Use, Permitted Use of Mobile Application,

2 https://www.axs.com/about-terms-of-use_US_v1.html (Dec. 14, 2018) (last accessed
3 November 6, 2023).
4 51. Similarly, Plaintiff’s Terms of Service provide the following limitations
5 and prohibitions relating to use of Plaintiff’s trademarks:
6 The trademarks, logos, and service marks displayed on the Services
7 (collectively the “Trademarks”) are the registered and unregistered
trademarks owned by us or by our licensors, service providers and or
8 others that have granted us permission to use such Trademarks. You
may not use the Trademarks in connection with any product or service
9 that is not offered by us, and users are not granted any license or right
to use the Trademarks for commercial or any unauthorized purposes.
10
AXS Terms of Use, Limited License; Restrictions, https://www.axs.com/about-
11
terms-of-use_US_v1.html (Dec. 14, 2018) (last accessed November 6, 2023).
12
13 VI. DEFENDANTS’ INFRINGING AND ILLICIT
COUNTERFIETING OPERATIONS
14
52. This case relates to Defendants’ activities with respect to the marketing,
15
sale, and delivery of resale tickets in the secondary market for entertainment and
16
sporting event tickets.
17
53. Defendants operate online retail platforms and/or ticket delivery
18
services. As set forth herein, and on information and belief, they have marketed,
19
distributed, sold, displayed, and/or delivered counterfeit AXS tickets to consumers
20
for a variety of events in this judicial district and beyond. Further, IRS and ETC are
21
engaged in additional widespread trademark infringement and unfair competition in
22
addition to the counterfeit ticket schemes as set forth herein.
23
IRS and ETC Deliver Counterfeit AXS Digital Tickets to
24
Unsuspecting Consumers in Cooperation with Verified-
25 Ticket.com
26 54. Defendant IRS targets consumers by marketing, distributing, and selling
27 tickets to events in the Los Angeles area. For starters, shown below is IRS’s tickets-
28 center.com website showing that as of November 3, 2023, IRS was promoting and
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1 offering for sale tickets to several events in Los Angeles and the surrounding areas:
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20 55. Similarly, Defendant ETC targets consumers by marketing, distributing,
21 and selling tickets to events in the Los Angeles area. Shown below is the
22 eventticketscenter.com website showing that as of November 3, 2023, ETC was
23 promoting and offering for sale tickets to several events in Los Angeles and the
24 surrounding areas:
25
26
27
28
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1
2
3
4
5
6
7
8
9
10
11
12
13
14 56. IRS and ETC sell, facilitate, participate in, allow, deliver or are
15 otherwise complicit in counterfeit AXS tickets being sold through tickets-center.com
16 and eventticketscenter.com, respectively, to purchasers who are duped into believing
17 that the tickets are genuine. On information and belief, agents of IRS and ETC either
18 know of this rampant practice and have failed to stop it, or these agents are actively
19 involved in the process.
20 57. For its part in this operation, Verified-Ticket.com sells, facilitates,
21 participates in, allows, or is otherwise complicit in delivering counterfeit AXS tickets
22 to these unsuspecting consumers. On information and belief, this conduct is occurring
23 here within this judicial district and beyond.
24 58. As just one example of this fraudulent scheme, earlier this year, an
25 unsuspecting consumer by the name of “Nate” purchased a ticket from Defendant
26 IRS’s tickets-center.com to a Washington Wizards game set to be played on
27 February 16, 2023. He received the following email verification generated by
28 tickets-center.com informing him that he had purchased a ticket for this game in
-19-
1 69. Even if a genuine AXS ticket is sold on the IRS website, IRS would not
2 be responsible for the electronic delivery of that ticket in any way, shape, or form.
3 Instead, if the resale is of a genuine AXS ticket, the consumer who purchased the
4 ticket off of the IRS website would get an email from AXS instructing the consumer
5 to download the AXS App (or log into their AXS account) so that the ticket could be
6 delivered safely and securely using the AXS Mobile ID technology.
7 70. Attached hereto as Exhibit L is a true and correct copy of multiple
8 digital ticket transactions where tickets-center.com indicated it would charge a fee in
9 conjunction with the consumer taking delivery of the ticket via “Flash Seats” or
10 “AXS Mobile ID.”
11 71. IRS’s use of Plaintiff’s trademarks is likely to cause confusion,
12 deception, and mistake that will be exceedingly harmful to Plaintiff. For starters,
13 charging a “fee” for the supposed “Flash Seats” delivery method makes it look like
14 Plaintiff approves, sponsors, or otherwise endorses IRS and its commercial activity.
15 But Plaintiff does not approve, sponsor, other otherwise endorse IRS. In fact, Plaintiff
16 wants nothing to do with IRS because tickets-center.com has a horrible reputation in
17 the digital ticket sale and delivery industry.
18 72. For example, trustpilot.com is a third-party consumer review website. It
19 shows that Defendant IRS’s tickets-center.com business has an average 1.1 star
20 review from 387 consumers. 6 Indeed, 98% of reviewers have given tickets-
21 center.com a one star review and many have characterized tickets-center.com as a
22 “scam.” “Clowns,” “Gougers,” and “Thieves” are just a few of the choice epithets
23 that consumers use to describe tickets-center.com. Some examples of the reviews
24 are shown below:
25
26
27
6
A 1 star rating does not imply even a slight degree of satisfaction because in order
28
to leave a review, a consumer has to give at least a 1 star rating.
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1
2
3
4
5
6
7
8
9
10
11
12
13 Attached hereto as Exhibit M are true and correct copies of the reviews from
14 trustpilot.com.
15 73. Defendant IRS’s tickets-center.com has similarly racked up hundreds of
16 horrible reviews as depicted on the website curated by the Better Business Bureau
17 (“BBB”) website, bbb.org. Attached hereto as Exhibit N is a true and correct copy
18 of the BBB listing for tickets-center.com, showing that it is not accredited by the
19 BBB and showing numerous aggrieved reviewers. Descriptive terms like “Trash,”
20 “Scam,” and “Absurd” are routinely used by reviewers. According to the BBB’s
21 website, in just the last three years alone there have been approximately 3,416
22 complaints lodged with the BBB about tickets-center.com. Just some of the examples
23 of the reviews are reproduced below:
24
25
26
27
28
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1
2
3
4
5 74. These illicit acts are causing and are likely to cause significant damages
6 and harm to Plaintiff’s reputation. They are also causing and are likely to cause
7 significant harm to consumers as well.
8 ETC’s Independent Acts of Infringement and Unfair
Competition
9
75. Defendant ETC is likewise engaged in independent acts of trademark
10
infringement and unfair competition, separate and apart from the fraudulent fake
11
ticket scheme detailed above. As noted earlier, Defendant ETC advertises for sale
12
numerous digital tickets for concerts and other Los Angeles-based events on
13
eventticketscenter.com. In advertising and promoting many of these events,
14
eventticketscenter.com notes that the delivery method for these tickets will be
15
accomplished by “Flash Seats.”
16
76. Defendant ETC charges consumers “service and delivery fees.” While
17
eventticketscenter.com does not display an itemized list of such fees to consumers,
18
on information and belief, Defendant ETC is charging consumers a “delivery fee” of
19
unknown amount for the delivery of tickets using Flash Seats. For example, below
20
is a screenshot showing that for an $85 dollar ticket delivered via Flash Seats for a
21
hockey match in Los Angeles, a consumer would be charged a total of “$120.45
22
which includes tickets, service, and delivery fees” (emphasis supplied).
23
24
25
26
27
28
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1 charging a “delivery fee” for the supposed “Flash Seats” delivery method makes it
2 look like Plaintiff approves, sponsors, or otherwise endorses ETC and its commercial
3 activity. But Plaintiff does not approve, sponsor, other otherwise endorse ETC. In
4 fact, Plaintiff wants nothing to do with ETC because—just like IRS—ETC has a
5 horrible reputation in the digital ticket sale and delivery industry.
6 80. For example, ETC and its eventticketscenter.com website have
7 hundreds of negative reviews on the BBB website, resulting in a total rating of 1.15
8 out of 5 stars. Attached hereto as Exhibit O is a true and correct copy of the BBB
9 listing for ETC, showing that it has numerous reviews calling the website a “Scam”
10 and noting its “fraudulent” activity. Below are just some of the negative reviews:
11
12
13
14
15
16
17
18
19
20 81. Defendant ETC’s conduct is causing and is likely to cause significant
21 damages and harm to Plaintiff’s reputation. It is causing and is likely to cause

23 Amosa.app is Selling and Distributing Counterfeit AXS
Tickets in this Judicial District
24
82. For its part, Amosa.app (and the individual(s) behind it) are engaged in
25
a similar scheme to create and/or sell and distribute counterfeit AXS digital tickets
26
in this judicial district and beyond. As an initial matter, and as referenced above,
27
amosa.app is a domain name registered through the domain name registrar, Dynadot,
28
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1 LLC. “axs.amosa.app” is a “subdomain” where “axs” was added by the individual

2 or individuals operating the amosa.app domain. Including axs as a subdomain makes
3 it appear to consumers that they have purchased genuine AXS tickets when, in reality,
4 they have not.
5 83. On or about March 30, 2022, a representative from the LA Clippers box
6 office contacted AXS to inform them of a consumer who had received “fraudulent
7 tickets” to an LA Clippers v. Utah Jazz game in Los Angeles. The tickets appeared
8 to be authentic AXS digital tickets; however, when the LA Clippers box office
9 scanned the QR code, the seat numbers shown in the system did not match the seat
10 numbers shown on the tickets. The purchaser of the tickets was denied entry because
11 the ticket information did not match and because the purchaser showed the QR code
12 associated with the tickets to the box office on a website rather than in the AXS App.
13 Below is an image of the website that hosted the counterfeit tickets, showing that it
14 is Defendant Amosa’s amosa.app website:
15
16
17
18 84. As another example, on or about November 8, 2022, a consumer was
19 attending the LA Kings v. Minnesota Wild game at Crypto.com Arena in Los
20 Angeles. The consumer purchased three tickets from a third party retail platform and
21 received what appeared to be authentic AXS digital tickets. However, the digital
22 tickets did not appear in the AXS App or in the LA Kings app. Rather the consumer
23 received the tickets from the Defendant Amosa.app platform and presented the
24 tickets to security at Cypto.com Arena through a web-browser. The venue was unable
25 to authenticate that the consumer was the rightful owner of the tickets. Below is an
26 image of the consumer’s phone, showing the counterfeit tickets, which look exactly
27 like authentic AXS digital tickets. The second image on the right is a close up of that
28 same phone photograph showing that the tickets were delivered and presented
-29-
1 tickets and consumers are likely to believe that Amosa is associated with, sponsored
2 by, or affiliated with AXS and Amosa’s use of the AXS Marks in its subdomain
3 “axs.amosa.app” makes it look like Plaintiff approves, sponsors, or otherwise
4 endorses Amosa.app and its commercial activity. Plaintiff does not approve, sponsor,
5 or otherwise endorse Amosa.
9 Secure.Tickets is Selling and Distributing Counterfeit AXS
Tickets in this Judicial District
10
89. Like Amosa, Defendant Secure.Tickets (and the individual(s) behind it)
11
is engaged in a scheme to create and/or sell and distribute counterfeit AXS digital
12
tickets in this judicial district and beyond.
13
90. On or about October 19, 2023, a consumer attending the Denver
14
Nuggets v. LA Clippers game at Crypto.com Arena in Los Angeles presented what
15
appeared to be an AXS digital ticket to representatives at the box office when entering
16
the Arena. However, the digital ticket did not appear in the AXS App. Rather, the
17
consumer presented the ticket through a web-browser associated with the domain
18
name secure.tickets. The digital ticket had the elements of a genuine AXS digital
19
ticket, including the trademark AXS Mobile ID, the AXS watermark, and the deep
20
purple backdrop. The ticket even had a rotating QR code, although it showed a
21
different seat location and amount when scanned by representatives at the box office.
22
Below is an image of the consumer’s phone screen, showing the counterfeit ticket,
23
and a close up of the same phone screen showing that the ticket was delivered and
24
presented through the domain name associated with Defendant Secure.Tickets:
25
26
27
28
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1 associated with, sponsored by, or affiliated with AXS. Plaintiff does not approve,
2 sponsor, or otherwise endorse Secure.Tickets.
6 VII. CAUSES OF ACTION
7 First Cause of Action (All Defendants)
8 Copyright Infringement Under 17 U.S.C. § 101, et seq.
9 95. Plaintiff re-alleges and incorporates all of the allegations set forth in the
10 preceding paragraphs as if fully set forth herein.
11 96. Plaintiff’s AXS App, including its source code and user interface and
12 all protectable screen displays generated by the source code including digital tickets,
13 constitutes an original work of authorship and copyrightable subjected matter under
14 the laws of the United States.
15 97. Plaintiff’s Copyright Registration No. TX0009296416, relating to the
16 iOS version of the AXS App, is valid and in full force and effect.
17 98. Plaintiff’s Copyright Registration No. TX0009300435, relating to the
18 Android version of the AXS App, is valid and in full force and effect.
19 99. Plaintiff is the owner of all exclusive rights in and to the AXS App
20 Copyrights and the Copyright Registrations are prima facie evidence of validity.
21 100. On information and belief, Defendants have downloaded or accessed the
22 AXS App and bypassed security and access control measures
23
24 to decompile, reverse engineer, disassemble or otherwise
25 modify and copy data stored or transmitted by the AXS App to create lookalike
26 websites.
27 101. Defendants have copied, created derivative works of, and/or distributed
28 copies to consumers, and publicly displayed Plaintiff’s protected works, all without
-33-
1 Plaintiff’s authority or consent.

2 102. On information and belief, Defendants’ actions were and are intentional,
3 willful, wanton, and/or performed in complete disregard of Plaintiff’s rights.
4 103. These actions constitute infringement of Plaintiff’s exclusive rights in
5 violation of the Copyright Act, 17 U.S.C. §§ 106 and 501.
6 104. Plaintiff is entitled to preliminary and permanent injunctive relief
7 pursuant to 17 U.S.C. § 502. Plaintiff has no adequate remedy at law for this
8 wrongful conduct because Plaintiff’s copyrights in the AXS App are unique and
9 valuable property without a readily determinable market value. Thus, continued and
10 repeated infringement harms Plaintiff such that Plaintiff cannot be made whole with
11 a monetary award, and this wrongful conduct, and the consequential damages to
12 Plaintiff, is continuing.
13 105. Plaintiff has been and will continue to be damaged by the wrongful
14 infringement of Plaintiff’s copyrights, and Defendants have been and continue to be
15 unjustly enriched in an amount to be proven at trial.
16 106. Plaintiff is entitled to recover all available damages authorized under the
17 Copyright Act.
18 Second Cause of Action (All Defendants)
19 Violation of Digital Millennium Copyright Act Under 17 U.S.C. § 1201
22 108. Plaintiff’s AXS App, including its source code and user interface and
23 all screen displays generated by the source code including digital tickets, constitutes
24 an original work of authorship and copyrightable subject matter under the laws of the
25 United States. The AXS App is covered by Copyright Registration No.
26 TX0009296416 and Copyright Registration No. TX0009300435.
27 109. Plaintiff employs technological security measures and other access
28 controls to protect and control access to and restrict use of copyrighted protected
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1 elements of the AXS App.

2 110. On information and belief, Defendants circumvented or bypassed
3 Plaintiff’s access controls to knowingly and intentionally gain unauthorized access
4 to copyright protected elements of the AXS App to decompile, reverse engineer,
5 disassemble or otherwise modify and copy data stored or transmitted by the AXS
6 App. On information and belief, Defendants used the information obtained through
7 this circumvention to create, offer for sale, sell, display, and/or distribute counterfeit
8 AXS tickets.
9 111. The circumvention of the technological security and access control
10 measures Plaintiff uses to control access to a work or works protected by copyright
11 is in violation of 17 U.S.C. § 1201(a)(1) of the Digital Millennium Copyright Act.
12 112. Plaintiff has been and will continue to be damaged by Defendants’
13 conduct in an amount to be proven at trial.
14 113. Plaintiff is entitled to the relief provided by 17 U.S.C. § 1203, including
15 but not limited to injunctive relief, actual, and/or statutory damages, and attorneys’
16 fees.
17 114. This improper conduct as will cause further irreparable injury to
18 Plaintiff if Defendants are not restrained by this Court. Plaintiff is entitled to
19 preliminary and permanent injunctive relief and Plaintiff’s remedies at law are
20 inadequate to compensate for this harm.
21 Third Cause of Action (All Defendants)
22 Trademark Counterfeiting Under 15 U.S.C. § 1114, et seq.
25 116. Plaintiff owns the AXS Registrations covering the AXS Marks, which
26 are valid and in full force and effect. Plaintiff is the owner of all rights, title, and
27 interests in the AXS Registrations.
28 117. Without Plaintiff’s authorization or consent, Defendants have used the
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1 AXS Marks in U.S. commerce to market, promote, offer for sale, sell and distribute
2 counterfeit AXS tickets. Defendants intentionally reproduced, copied, and/or
3 colorably imitated the AXS Marks and/or used designations that are identical to, or
4 substantially indistinguishable from the AXS Marks on or in connection with the
5 counterfeit tickets.
6 118. Defendants have advertised, promoted, offered for sale, sold, displayed
7 and/or distributed counterfeit AXS tickets to consumers in or affecting interstate
8 commerce, and/or have acted with reckless disregard of Plaintiff’s rights in and to
9 the AXS Marks through their participation in such activities.
10 119. Defendants’ unauthorized use of the AXS Marks is likely to cause
11 confusion, deception or mistake in the marketplace because consumers are likely to
12 believe there is a connection, affiliation, or sponsorship between Plaintiff and
13 Defendants. Defendants’ actions constitute willful counterfeiting of the AXS Marks
14 in violation of 15 U.S.C. §§ 1114(1)(a)-(b), 1116(d), and 1117(b)-(c).
15 120. As a direct and proximate cause of Defendants’ conduct, Plaintiff has
16 suffered and will continue to suffer loss of income, profits, and goodwill, and
17 Defendants will continue to unfairly acquire income, profits, and goodwill.
18 121. Defendants’ conduct will cause further irreparable injury to Plaintiff if
19 Defendants are not restrained by this Court. Plaintiff is entitled to preliminary and
20 permanent injunctive relief and Plaintiff’s remedies at law are inadequate to
21 compensate for this harm.
22 Fourth Cause of Action (All Defendants)
23 Trademark Infringement Under 15 U.S.C. § 1114, et seq.
26 123. Plaintiff owns the AXS Registrations covering the AXS Marks, which
27 are valid and in full force and effect. Plaintiff is the owner of all right, title, and
28 interest in and to the AXS Registrations.
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1 124. Defendants have used the AXS Marks in U.S. commerce to market,
2 promote, offer for sale, sell, and distribute tickets. Defendants’ unauthorized use of
3 the AXS Marks is likely to cause confusion, deception or mistake in the marketplace
4 because consumers are likely to believe there is a connection, affiliation, or
5 sponsorship between Plaintiff and Defendants.
6 125. Defendants’ conduct constitutes infringement of Plaintiff’s AXS
7 Registrations in violation of Section 32(1) of the Lanham Act, 15 U.S.C. § 1114(1).
8 126. On information and belief, Defendants’ conduct has been willful and in
9 bad faith and Defendants have used the AXS Marks with the intention of misleading,
10 deceiving, or confusing consumers as to the origin of their goods and for the purpose
11 of trading on Plaintiff’s reputation and goodwill.
19 Fifth Cause of Action (All Defendants)
20 Unfair Competition and False Designation of Origin
21 Under 15 U.S.C. § 1125, et seq.
24 130. Plaintiff has adopted and used the AXS Marks in U.S. commerce, which
25 consumers have come to associate exclusively with Plaintiff. Plaintiff is the owner
26 of all right, title, and interest in and to the AXS Marks. The AXS Marks are non-
27 functional.
28 131. Defendants have used the AXS Marks in U.S. commerce to market,
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1 promote, offer for sale, sell and distribute tickets. Defendants’ unauthorized use of
2 the AXS Marks is likely to cause confusion, deception or mistake in the marketplace
3 because consumers are likely to believe there is a connection, affiliation, or
4 sponsorship between Plaintiff and Defendants.
5 132. Defendants’ conduct constitutes federal unfair competition and false
6 designation of origin in violation of Section 43(a) of the Lanham Act, 15 U.S.C.
7 § 1125(a).
8 133. On information and belief, Defendants’ conduct has been willful and in
9 bad faith and Defendants have used the AXS Marks with the intention of misleading,
10 deceiving, or confusing consumers as to the origin of their goods and for the purpose
11 of trading on Plaintiff’s reputation and goodwill.
19 Sixth Cause of Action (All Defendants)
20 State Statutory Unfair Competition
21 Under Cal. Bus. & Prof. Code § 17200, et seq.
26 of all rights, title, and interest in the AXS Marks. The AXS Marks are non-functional.
27 138. On information and belief, Defendants have intentionally appropriated
28 the AXS Marks with the intent of causing confusion, mistake, and deception as to the
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1 source of their goods and services with the intent to pass off their goods and services
2 as those of Plaintiff.
3 139. Defendants’ conduct in connection with the offer for sale, sale, and
4 advertisement of tickets has violated the unfair competition laws of the State of
5 California, specifically Cal. Bus. & Prof. Code § 17200 et seq.
6 140. On information and belief, Defendants’ conduct is willful, intentional,
7 malicious, and in bad faith.
9 been and will continue to be irreparably harmed and damaged. Plaintiff’s remedies
10 at law are inadequate to compensate for this harm.
11 Seventh Cause of Action (All Defendants)
12 Common Law False Designation of Origin & Unfair Competition
17 of all rights, title, and interest in the AXS Marks.
18 144. Defendants are promoting, advertising, selling, and distributing goods
19 and services under the AXS Marks, in violation of California’s common law of unfair
20 competition.
21 145. Defendants’ unauthorized use of the AXS Marks for goods and services
22 competing with Plaintiff’s goods and services is likely to cause confusion, deception,
23 or mistake in the marketplace as to the source or sponsorship of Defendants goods
24 and services.
27 147. As a direct and proximate result of Defendants’ conduct, Plaintiff has
28 suffered and will continue to suffer irreparable loss of income, profits, and good will,
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1 and Defendants will continue to unfairly acquire income, profits, and goodwill. As
2 a direct and proximate cause of Defendants’ conduct, Plaintiff has been and will
3 continue to be irreparably harmed and damaged. Plaintiff’s remedies at law are
4 inadequate to compensate for this harm.
6 Defendants are not restrained by this Court from further violation of Plaintiff’s rights.
7 Eighth Cause of Action
8 (Against Defendants IRS, ETC and Verified-Ticket.com)
9 Civil Conspiracy
12 150. Plaintiff alleges that Defendants IRS and Verified-Ticket.com formed a
13 plan to promote, offer for sale, sell, display, and distribute counterfeit tickets using
14 the AXS Marks and protected elements of the AXS App.
15 151. On information and belief, Defendants IRS and Verified-Ticket.com
16 agreed to the plan and were aware that each other planned to participate in the plan
17 and that the plan was unlawful and fraudulent.
18 152. Plaintiff alleges that Defendants ETC and Verified-Ticket.com formed
19 a plan to promote, offer for sale, sell, display, and distribute counterfeit tickets using
20 the AXS Marks and protected elements of the AXS App.
21 153. On information and belief, Defendants ETC and Verified-Ticket.com
22 agreed to the plan and were aware that each other planned to participate in the plan
23 and that the plan was unlawful and fraudulent.
24 154. As a result of this conspiracy, Plaintiff has been harmed because, among
25 other things, Defendants have derived sales, revenues, and other benefits from their
26 promotion, offering for sale, selling, display and distribution of counterfeit tickets,
27 all at Plaintiff’s economic and reputational expense.
-40-

3 Defendants are not restrained by this Court from further violation of Plaintiff’s rights.
4 Ninth Cause of Action (All Defendants)
5 Breach of Contract
8 158. Plaintiff’s Terms of Use is a valid and enforceable contract. On
9 information and belief, Defendants used the AXS Platform and/or downloaded the
10 AXS App.
11 159. Plaintiff’s Terms of Use provide notice that Plaintiff’s “Mobile App is
12 protected by copyright” and that it or its contents “may not be sold, redistributed,
13 copied, made available to the public, or part of a derivative work created by you
14 without the express written consent of AXS” and that users “may not attempt to
15 decompile, reverse engineer, disassemble or otherwise modify the Mobile App, or in
16 any way compromise the security of data stores or transmitted by [AXS’s] Mobile
17 App.”
18 160. Defendants agreed to Plaintiff’s Terms of Use by using the AXS
19 Platform and/or using, accessing, or downloading the AXS App.
20 161. Defendants have breached the Terms of Use by copying, mimicking,
21 emulating, creating derivative works of, distributing copies to consumers, and
22 publicly displaying Plaintiff’s protected works, all without Plaintiff’s authority or
23 consent.
24 162. Defendants have breached the Terms of Use by circumventing or
25 bypassing Plaintiff’s access controls to knowingly and intentionally gain
26 unauthorized access to copyright protected elements of the AXS App in order to
27 decompile, reverse engineer, disassemble or otherwise modify and copy protected
28 elements of the AXS App.
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1 163. Plaintiff’s Terms of Use also provides notice that “the trademarks,
2 logos, and service marks displayed on the Services (collectively the “Trademarks”)
3 are registered and unregistered trademarks owned by [AXS] or by our licensors,
4 service providers and or others that may have granted us permission to use such
5 Trademarks” and that users “may not use the Trademarks in connection with any
6 products or service that is not offered by [AXS], and users are not granted any license
7 or right to use the Trademarks for commercial or any unauthorized purposes.”
8 164. Defendants have breached the Terms of Use by using the AXS Marks
9 in U.S. commerce to market, promote, offer for sale, sell and distribute counterfeit
10 tickets without Plaintiff’s authorization or consent. Defendants intentionally
11 reproduced, copied, and/or colorably imitated the AXS Marks and/or used
12 designations that are identical to, or substantially indistinguishable from the AXS
13 Marks on or in connection with the counterfeit tickets.
16 166. As a result of Defendants’ breach, Plaintiff has suffered and continues
17 to suffer monetary and non-monetary injury and harm in an amount to be proven at
18 trial.
19 167. As a result of Defendants’ ongoing breach, Plaintiff has been injured
20 and faces irreparable harm. Plaintiff is threatened with losing its competitive
21 advantage, customers, and goodwill that would be impossible to fully compensate
22 unless Defendants are enjoined and restrained by order of this Court.
23 VIII. PRAYER FOR RELIEF
24 WHEREFORE, Plaintiff demands judgment and relief against Defendants and
25 respectfully requests that this Court:
26 1. Preliminarily and then permanently enjoin, restrain, and forbid
27 Defendants, their officers, agents, servants, employees, attorneys, successors or
28 assigns, and all persons or entities acting in concert or participation with any of them
-42-
1 from:
2 (a) copying, mimicking, emulating, creating derivative works from,
3 distributing copies of, offering for sale and/or publicly displaying any tickets
4 or other products that incorporate any portion of AXS’s copyright protected
5 works;
6 (b) imitating, copying, duplicating or otherwise making any use of the AXS
7 Marks, or any mark confusingly similar to the AXS Marks in any manner;
8 (c) using any false designation or origin or false description or representation
9 or any other thing calculated or likely to cause confusion, mistake, or deception
10 in the marketplace as to the source of Defendants’ goods and services or any
11 belief that Defendants’ goods and services are in any way associated with,
12 affiliated with, or related to AXS or AXS’s goods and services;
13 (d) engaging in any activity constituting unfair competition with AXS or with
14 AXS’s rights in, or to use, the AXS Marks;
15 (e) further using the AXS Marks, or confusingly similar variations thereof, in
16 or as a part of any advertising, marketing and/or media material, web page text,
17 social media platform, domain name, email, or other communication;
18 (f) accessing, decompiling, reverse engineering, disassembling or otherwise
19 modifying the AXS App;
20 (g) assisting, aiding or abetting another person, entity, or business in engaging
21 in or performing any of the activities enumerated above.
22 2. Direct Defendants to file with the Court and serve on counsel for AXS,
23 within thirty days after entry of any injunction issued by this Court, a sworn statement
24 as provided in 15 U.S.C. § 1116;
25 3. Award AXS a money judgment, granting compensatory relief for
26 Defendants’ willful copyright infringement, the precise amount to be proven at trial.
28 Defendants’ willful violations of the Digital Millennium Copyright Act, including
-43-
1 either actual damages, or statutory damages as provided for pursuant to 17 U.S.C.

2 § 1203.
4 Defendants’ willful trademark counterfeiting, the precise amount to be proven at trial,
5 or in the alternative, statutory damages as permitted by 15 U.S.C. § 1117(c), against
6 each Defendant in an amount of $2,000,000 per counterfeit mark per type of goods
7 or services sold;
8 6. Direct Defendants to account to AXS for its profits arising from the
9 conduct complained of herein, pursuant to 15 U.S.C. § 1117(a);
10 7. Award AXS its actual damages incurred as a consequence of
11 Defendants’ conduct as described herein, pursuant to 15 U.S.C. § 1117(a), 15 U.S.C.
12 § 1125(a), and California law;
13 8. Award AXS its reasonable attorneys’ fees and taxable costs and
14 disbursements of this action, pursuant to the Lanham Act, the Copyright Act, and the
15 inherent authority of the Court;
16 9. Award AXS trebled damages as provided for under the Lanham Act;
17 10. An order finding that Defendants IRS, ETC and Verified-Ticket.com
18 engaged in a conspiracy and are jointly and severally liable for any and all remedies
19 granted by this Court;
20 11. Award AXS prejudgment interest at the rate provided for under
21 California law as applicable; and
22 12. Award AXS such other and further relief as the Court deems just and
23 equitable.
24 IX. JURY DEMAND
25 AXS demands that all claims or causes of action raised in this Complaint be
26 tried to a jury to the fullest extent possible under the United States Constitution.
27
28
-44-
1
Dated: January 16, 2024 DORSEY & WHITNEY LLP
2
3 By: /s/ J. Michael Keyes______
J. Michael Keyes (SBN 262281)
4 [email protected]
Connor J. Hansen (pro hac vice)
5 [email protected]
Columbia Center
6 701 Fifth Avenue, Suite 6100
Seattle, WA
7 Telephone: 206.903.8800
Facsimile: 206.903.8820
8
DORSEY & WHITNEY LLP
9 Kent J. Schmidt (SBN 195969)
[email protected]
10 600 Anton Boulevard, Suite 200
Costa Mesa, CA 92626
11 Telephone: 714.800.1400
Facsimile: 714.800.1499
12
Attorneys for Plaintiff AXS Group LLC
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-45-
1 VERIFICATION
2 I, Alex Hazboun, declare as follows:
3 1. I am the Chief Technology Officer for Plaintiff AXS Group LLC
4 ("AXS"). I have reviewed the foregoing Verified Complaint and verify that the
5 statements made therein are true and correct to the best of my knowledge,
6 information, and belief.
7 2. I have personal knowledge of AXS, AXS's activities, AXS's copyright
8 and trademark rights, and AXS's interactions with Defendants, including those set
9 forth out in the foregoing Verified Complaint, and if called to testify, I would testify
10 as to the matters stated therein.
11 3. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury under
12 the laws of the United States that the foregoing factual statements in the Verified
13 Complaint about myself, AXS, AXS's activities, AXS's copyright and trademark
14 rights, and AXS's interactions with Defendants are true and correct factual
15 statements.
16
17 Executed on December .12., 2023 in Los Angeles, California.
18
19 .A/ex h
20 Alex Hazboun
21
22
23
24
25
26
27
28
-46-
VERIFIED COMPLAINT
Case 2:24-cv-00377-SPG-E Document 1-1 Filed 01/16/24 Page 1 of 5 Page ID #:47
Exhibit A
Case
6/30/23, 10:46 AM 2:24-cv-00377-SPG-E Document 1-1 Whois
Filed 01/16/24 Page 2 of 5 Page ID #:48
verified-tickets.com
Enter Domain or IP WHOIS
DOMAINS WEBSITE CLOUD HOSTING SERVERS EMAIL SECURITY WHOIS SUPPORT LOGIN 0
veri ed-tickets.com Updated 27 days ago
Domain Information
Domain: veri ed-tickets.com

.space
Registrar: Google LLC
$
24.88 $
0.88
Registered On: 2021-09-15 BUY NOW
Expires On: 2023-09-15

*Offer ends 30th June 2023
Updated On: 2022-09-15
Status: clientTransferProhibited On Sale!
Name Servers: ns1.a2hosting.com

ns2.a2hosting.com
ns3.a2hosting.com
ns4.a2hosting.com
Registrant Contact .PRO @ $3.88 $28.88
Name: Contact Privacy Inc. Customer 7151571251
Organization: Contact Privacy Inc. Customer 7151571251
Street: 96 Mowat Ave
City: Toronto
State: ON
Postal Code: M4K 3K1
Country: CA
Phone: +1.4165385487
Email: https://domains.google.com/contactregistrant?domain=veri ed-

tickets.com
Administrative Contact
City: Toronto
State: ON
Country: CA
https://www.whois.com/whois/verified-tickets.com 1/4
Case
Phone: +1.4165385487

tickets.com
Technical Contact
City: Toronto
State: ON
Country: CA
Phone: +1.4165385487

tickets.com
Raw Whois Data

Domain Name: verified-tickets.com
Registry Domain ID: 2641229935_DOMAIN_COM-VRSN
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Case
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Name Server: NS1.A2HOSTING.COM
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English
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resource (IP Network or ASN) (FAQ) (/en/faq)
secure.tickets Lookup
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clientTransferProhibited (https://icann.org/epp#clientTransferProhibited)
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ns-1722.awsdns-23.co.uk
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Updated: 2023-09-14 07:58:25 UTC
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Case
Email: 2:24-cv-00377-SPG-E Document 1-3 Filed 01/16/24 Page 4 of 6 Page ID #:59
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Exhibit D
Exhibit E
Exhibit F
Exhibit G
AEG has Ticketmaster in its sights; The L.A.-based entertainment giant

ramps up its AXS ticket-selling business at Staples, other sites. - Correction
Appended
Los Angeles Times
February 4, 2013 Monday
Home Edition
Correction Appended
Copyright 2013 Los Angeles Times All Rights Reserved
Section: CALENDAR; Entertainment Desk; Part D; Pg. 1

Length: 883 words
Byline: Todd Martens, Wesley Lowery
Body
Ticketmaster, long the dominant player in the concert ticket space, now has major company.
Los Angeles-based AEG, the sports and entertainment empire that owns Staples Center, Nokia Theatre,
L.A. Live, the Kings and a minority stake in the Lakers, is angling to reinvent the ticketing business. It's
counting on Staples Center, the busiest concert venue in the United States, to get there.
AEG is now selling concert tickets at its trio of L.A. Live venues via its 18-month-old AXS ticketing
platform. It's the company's attempt to build a national rival to Ticketmaster and challenge the traditional
concert business, including battling scalpers.
A mobile app, for instance, will allow fans to order concessions from their seats.
"AXS is not a ticket transaction for us," said AEG Chief Executive Tim Leiweke. "AXS is a relationship for
us. From the moment someone says they want to go to an event, to the moment they walk out of the
event, we want to capture that relationship from beginning to end."
Tickets for a June 26 Beyonce concert go on sale Feb. 11 and that will be the first Staples Center show
available exclusively via AXS.com rather than Ticketmaster. For now, the trio of sports teams that call the
venue home will continue to use Ticketmaster, but that will change this summer with Kings tickets for
next season, said Bryan Perez, AEG's president of digital, ticket and media.
AEG has been considering a full-scale ticket service since antitrust regulators in 2010 approved
Ticketmaster's merger with AEG rival Live Nation Entertainment.
How big a deal is AXS to Ticketmaster?

AEG has Ticketmaster in its sights; The L.A.-based entertainment giant ramps up its AXS ticket-selling
business at Staples, other sites. - Correction Appended
"Our potential flow of tickets from our owned-and-operated venues to AXS is about 20 million" tickets,
Leiweke said.
Launching a ticketing firm can be fraught with peril, as Live Nation learned in 2009. The promoter opted
to launch its own ticketing service rather than renew with Ticketmaster, but the ticketing system struggled
with its first major on-sale. Days later, Live Nation and Ticketmaster announced they were merging.
Perez is confident that AXS is ready for the rush that selling Beyonce tickets could bring. "We build
buildings," he said, "so we're patient. We've been doing this for 18 months."
AEG's movement toward the development of its own ticketing arm makes strategic sense, said Dean
Budnick, executive editor of Relix Magazine and co-author of "Ticket Masters," the definitive book on the
event ticketing industry.
Ticketing events in its own venues, said Budnick, allows AEG to cash in on ticketing fees for events and
keep that money from going to Ticketmaster, which essentially amounts to subsidizing its chief
competitor, Live Nation.
Budnick theorizes that Live Nation has long been able to offer more money to performers by using ticket-
fee revenue. Now AEG may be able to increase pay for performers at some of its venues, making them
more competitive for major shows.
For concertgoers, this could mean higher ticket prices in cities where both Live Nation and AEG have
venues -- if the powerhouses enter bidding wars for major concert tours and events, Budnick said.
AEG's attempts to rewrite the ticketing rules include an endeavor dubbed AXS Invite that will allow ticket
purchasers to reserve adjacent seats and then invite friends via email or social networks to purchase
those seats.
Of even bigger interest to fans may be AEG's thoughts on how to thwart scalpers, who use computers to
bulk-buy tickets. "The current method of selling tickets is like Black Friday," Perez says. "You open the
doors at midnight, and people get trampled to death."
AEG's solution is Fair AXS, which will allow fans to sign up to purchase tickets up to a week in advance
of the on-sale date. Customers can select up to three sections in which they would like to sit, and tickets
will be purchased in advance via a lottery system. If tickets remain, there will be a general on-sale.
"If it's a big-bang on-sale, and everyone has to buy at once, naturally the guy with the hardware to
overwhelm the system is going to have the advantage," Perez said. "There's a better way to do this."
There's another reason AEG wanted to launch a competitor to Ticketmaster: data. If there are, for
example, a lot of advance requests for tickets via Fair AXS, AEG can add shows. If there are few, the
company will learn earlier that interest is low and perhaps "that the prices should be lower and there
should be more marketing," Perez said.
AEG has also been buying and investing in technology companies such as Carbonhouse and ByPass to
ensure that it's more than just a platform to move tickets. The goal, said Perez, is that if a repeat Kings
customer walks into Staples Center, he can use an app to have his desired snack-bar items awaiting him
at his seat. Other fan-friendly aspects include an elimination of print-at-home fees and more transparent
ticketing costs, meaning consumers know up-front the final cost of a ticket.
Page 2 of 3
AEG has Ticketmaster in its sights; The L.A.-based entertainment giant ramps up its AXS ticket-selling
business at Staples, other sites. - Correction Appended
AEG also intends to pitch a service to other venue owners that allows them to sell tickets directly on their
sites rather than force consumers to visit a third-party destination. "This isn't about controlling the front
door," Perez said. "It's about controlling the process and making fundamental changes in the way people
purchase tickets."
--
[email protected]
[email protected]
Correction
AEG ticketing: An article in the Feb. 4 Calendar section about AEG's ticket platform, AXS, said Beyonce
would give a concert at Staples Center on June 26. The concert will be June 28.
Correction-Date: February 05, 2013
Graphic
PHOTO: "AXS is a relationship for us," says AEG Chief Executive Tim Leiweke, left, with Bryan Perez.
PHOTOGRAPHER:Bob Chamberlin L.A. Times PHOTO: AEG EXECS Bryan Perez, left, and Tim
Leiweke take a ride outside Staples Center's AXS box office. PHOTOGRAPHER:Bob Chamberlin Los
Angeles Times
Load-Date: February 5, 2013
End of Document
Page 3 of 3
Joint Venture Gives Live Music and Events a New TV Home

The New York Times
January 19, 2012 Thursday
Late Edition - Final
Copyright 2012 The New York Times Company
Section: Section B; Column 0; Business/Financial Desk; Pg. 6; MEDIA DECODER

Length: 816 words
Byline: By BRIAN STELTER
Body
6:25 p.m. Updated Ryan Seacrest, his talent agency CAA and the events promoter A.E.G. have been
talking for three years about making a cable channel for concerts, live events and other entertainment.
Now they have found the channel space for it at HDNet, the pioneering but poorly distributed channel
owned by the billionaire sports and media mogul Mark Cuban. This summer, HDNet will become AXS
TV, a joint venture of Mr. Cuban, Mr. Seacrest's media holding company, CAA and A.E.G.
''We're going to be able to take what I had hoped to do with HDNet - which was to be live, live, live - and
accelerate that considerably,'' Mr. Cuban said in a telephone interview before the deal was announced
Wednesday afternoon.
Similarly, Mr. Seacrest - who has been the host of the live Fox broadcast ''American Idol'' for nearly a
decade - said that ''music, live entertainment and live events'' would be the base of the channel. His
production company will conceive shows for the channel, as it already does for E! and Bravo, two
channels that are owned by Comcast. Financial terms of the joint venture were not disclosed, and Mr.
Cuban would not say whether he retained the majority ownership of HDNet. But Mr. Cuban and his new
partners said he would continue to run the channel, which was formed in 2001 as a destination for what
was then hard to find on television: high-definition programming.
HDNet grew as high-definition viewership grew, and Mr. Cuban said it was profitable last year. But to
date it is offered in just 27 million households, putting it out of reach of most of the roughly 100 million
cable and satellite households in the United States. The partners said Wednesday that their top priority
was gaining wider distribution. ''Distribution will be the first step,'' Mr. Seacrest said.
To that end, the partners announced that Dish Network had agreed to expand its distribution of the
channel to include non-high-definition homes. The change will allow AXS TV to have more than 35
million subscribers.
In an interesting twist, A.E.G. plans to provide what it calls ''unique ticketing opportunities'' to Dish
Network viewers of AXS TV. Mr. Cuban imagined a scenario that would have artists announcing a
concert, then directing viewers to log online with their Dish account to get ''first crack'' at tickets.
''AXS TV brings DISH subscribers a premier TV destination for concert-goers to watch the most popular
concert acts and provide opportunities for unique ticket sales at venues near them,'' Joe Clayton, the
chief executive of Dish, said in a statement.
A.E.G., the second-largest concert promoter in the United States behind Live Nation, began to roll out the
brand name AXS, pronounced ''access,'' last year with a Web site for concert ticket sales. Executives
said Wednesday that AXS TV will take advantage of the company's events and concert sites, including
the L.A. Live entertainment complex in Los Angeles and The O2 in London, and CAA's relationships with
artists and managers.
These are ''existing resources,'' said Tim Leiweke, the president of A.E.G., that can be mined for new
content for the cable channel and its Web site.
Stressing that artists not affiliated with A.E.G. or CAA will be welcomed, he said, ''This will be open to
anyone and everyone that wants to use this platform to allow an artist to go and talk to their fans.''
He added, ''That said, I guarantee that A.E.G. is going to use it.''
With the joint venture, Mr. Cuban is taking the same approach tried by several other channel owners -
partnering with other established brands to propel a channel forward. Discovery Communications has
partnerships with Oprah Winfrey for OWN and with Hasbro for a children's channel, The Hub.
The arrangement also acknowledges what he called an ''incredibly difficult'' environment for independent
channel owners. Most major cable channels are owned by media companies that have bundles of
channels, affording those companies some advantages in negotiations with producers and distributors.
Of the joint venture assets, he said, ''it's an incredible upgrade for us that would have been difficult -
impossible - to replicate.''
Some of the existing programming on HDNet, including mixed martial arts matches and the
newsmagazine ''Dan Rather Reports,'' will remain in place on AXS TV, Mr. Cuban said. A raunchier
subset of late-night shows - what he calls ''the unrated stuff'' - will be cut out.
Reflecting the emphasis on live TV, Mr. Cuban noted that Mr. Rather already has had some live
programs on HDNet, including coverage of the New Hampshire Republican primary last week. Mr.
Rather does not have a formal contract at HDNet; ''as long as he wants to be there, he's there,'' Mr.
Cuban said Wednesday, repeating what he has said in the past.
Mr. Cuban's other channel, HDNet Movies, will remain as-is.
This is a more complete version of the story than the one that appeared in print.
http://www.nytimes.com
Load-Date: January 21, 2012
Page 2 of 3
End of Document
Page 3 of 3
Ticketmaster Competitor To Unveil A Web Site

The New York Times
August 23, 2011 Tuesday
Late Edition - Final
Copyright 2011 The New York Times Company
Section: Section B; Column 0; Business/Financial Desk; Pg. 3

Length: 421 words
Byline: By BEN SISARIO
Body
In the latest volley of the entertainment industry's ticketing wars, the Anschutz Entertainment Group, a
concert promoter that owns major arenas like the Staples Center in Los Angeles and the O2 in London,
will begin selling tickets to its concerts this weekend through a sleek new Web site it has developed to
compete with Ticketmaster.
On Tuesday, A.E.G., which is owned by the Anschutz Company, will announce its new ticketing brand,
AXS (pronounced ''access''), and a Web site, axs.com, that on Saturday will begin selling tickets for
events at two spaces in Denver that A.E.G. operates, the Bluebird Theater and the Ogden Theater. The
company created axs.com with Outbox Enterprises, a ticketing start-up whose co-chief executive is
Fredric D. Rosen, Ticketmaster's chief for much of the 1980s and '90s.
In its announcement, A.E.G. refers to several aspects of ticketing that Ticketmaster consumers have long
complained about. Axs.com will display the full prices for tickets, counting all fees, and the company also
says it will never charge to let people print their tickets at home. (Over the last year Ticketmaster has
made efforts to disclose most of its fees up front and eliminate the print-at-home fee, although those
changes have not been made throughout the entire site.)
A.E.G. is using the Denver theaters as a test run, and plans to introduce the system to more theaters by
the end of the year. Timothy J. Leiweke, A.E.G.'s president and chief executive, said in an interview that
the company expected to begin selling tickets for the Staples Center by early 2012, and at the O2 after
the Olympic Games next summer in London.
The company began developing its own ticketing system after the merger of Live Nation, the world's
biggest concert promoter, and Ticketmaster in early 2010. As part of the Justice Department's conditions
for approving the deal, A.E.G. was allowed to license Ticketmaster's software, but instead it chose to
build its own service as a competitor.
A.E.G.'s deal with Outbox allows it to use that company's technology for a ''white label'' ticketing system,
meaning it would make generic tickets that individual theaters or arenas could adopt. But Mr. Leiweke
said in an interview that the company's goal was to build AXS into a consumer brand for all of A.E.G.'s
Ticketmaster Competitor To Unveil A Web Site
theaters and events. Eventually, he said, the site will include video segments from concerts or a
television network that A.E.G. is developing.
''You will start to see a lot less A.E.G. and a lot more of AXS,'' Mr. Leiweke said.
http://www.nytimes.com
Load-Date: August 23, 2011
End of Document
Page 2 of 2
Parkhub, AEG Partner to Bring Game-Changing Parking Experience to

Marquee Sports & Entertainment Venues; Multiyear Agreement Names
ParkHub the Official Parking Technology Partner of Multiple AEG Owned and
Operated Venues, Includes; Full Integration Across the AXS Ticketing
Platform
Business Wire
April 11, 2023 Tuesday 4:00 PM GMT
Copyright 2023 Business Wire, Inc.
Length: 1070 words

Dateline: DALLAS
Body
ParkHub, a technology company that provides integrated software, hardware, and payment services for
the global parking industry, and AEG, the world's leading sports and live entertainment company, have
launched a strategic partnership to enhance the parking experience for fans while adding operational
efficiencies to several AEG-owned and operated venues including Crypto.com Arena (Los Angeles, CA),
Dignity Health Sports Park (DHSP) (Carson, CA) and Texas Trust CU Theatre at Grand Prairie (Grand
Prairie, TX). The agreement, brokered by AEG Global Partnerships, makes ParkHub technology
available to all three AXS ticketed venues, creating a seamless integration between the AXS ticket
purchase platform and venue parking operations. Through ParkHub's mobile point-of-sale and parking
inventory solutions, the integration across the AXS purchase flow gives fans the option to conveniently
pre-purchase parking ahead of select events and easily validate their parking pass at the venue. In
addition, the firm's business intelligence platform, Suite, will enable AEG executives to further optimize
parking operations and the guest experience by providing real-time insights into their parking operation.
"Parking is the guest's first on-site point of contact for nearly every event. With some of the world's most
well-known sports and entertainment venues in our network, we place a premium on quality operations
and state-of-the-art services for our fans," said Tyler Verdery, Vice President, AEG Global Partnerships.
"ParkHub's ability to streamline parking efficiencies and handle large volumes of traffic for sports and live
entertainment venues complements our efforts to get guests out of lines and into seats faster."
"We have seen better traffic flow around the L.A. LIVE campus and the transactions are faster now with
ParkHub," said Bill Garner, Senior Director of Parking Operations at L.A. LIVE, Crypto.com Arena and
Microsoft Theater. "Being able to take credit cards at all of our lots has greatly improved the parking
operations. Being able to see live data while in the field has allowed us to better maximize all of our
parking lots."
"From my point of view, ParkHub has brought visibility to the daily operations of the parking system with
intuitive and informative reports in real time and at my fingertips," said Jim Madsen, Senior Vice
Parkhub, AEG Partner to Bring Game-Changing Parking Experience to Marquee Sports & Entertainment
Venues; Multiyear Agreement Names ParkHub the Official Parking ....
President, L.A. LIVE Operations. "I get a daily report at the end of the night and don't have to wait for
others to complete their task to see how we did. For the line staff, it has simplified the process and
reduced the need for multiple scanners."
In addition to real-time validation of pre-purchased parking, ParkHub also gives fans the option to
purchase on-site parking through Prime-ParkHub's handheld mobile point-of-sale terminal that accepts
and tracks all forms of payment. Guests will experience less time waiting in long lines and more time
enjoying the main event.
"We are continually exploring new and innovative ways to deliver world-class guest experiences at
Dignity Health Sports Park and our partnership with ParkHub helps us provide a new level of hospitality
and convenience, both of which we prioritize for the fans we host each year," said Adam Link, Vice
President of Event Services at Dignity Health Sports Park. "We're thrilled to be integrating their
technology into our parking operations and know that our fans will see it as a valuable new benefit that
gives them more time to focus on the fun and excitement of live events at our venue."
"We are excited to partner with AEG to provide our best-in-class parking hardware, software and services
to customers at world-class venues like Crypto.com Arena, Dignity Health Sports Park and Texas Trust
CU Theatre at Grand Prairie," said Chris Elliston, Chief Revenue Officer at ParkHub. "ParkHub gives
venues and parking operators the ability to quickly and easily authenticate parking passes sold via the
AXS platform, as well as accept cash, credit, and contactless NFC payments on-site, all while tracking
parking availability in real time. This partnership is a win for venues, a win for parking operators, and a
huge win for fans."
"Through the use of ParkHub's platform, we have been able to create a cashless transaction allowing
more vehicles to park in a shorter period of time," said Jeff Kehr, General Manager of Texas Trust
Theatre at Grand Prairie. "Their technology is driving more revenue to our bottom line and has enhanced
the fan's experience by integrating prepaid parking into the event ticketing process."
ABOUT PARKHUB
ParkHub is optimizing the world's journeys by providing cutting-edge enterprise technology to support the
global parking industry. The company's products offer contactless payment options, real-time operational
data, robust performance analytics, and leading integrations with ticketing and parking reservation
providers. For more information, visit parkhub.com .
ABOUT AEG
Headquartered in Los Angeles, California, AEG is the world's leading sports and live entertainment
company. The company operates in the following business segments: Facilities, which through its
affiliation with ASM Global, owns, manages or consults with more than 300 preeminent arenas, stadiums,
convention centers and performing arts venues around the world; Music through AEG Presents, which is
dedicated to all aspects of live contemporary music performances, including producing and promoting
global and regional concert tours, music and special events and world-renowned festivals such as the
Coachella Valley Music and Arts Festival; Real Estate, which develops world-class venues, as well as
major sports and entertainment districts like Crypto.com Arena and L.A. LIVE, Mercedes Platz in Berlin
and The O2 in London; Sports, as the world's largest operator of high-profile sporting events and sports
franchises including the LA Kings, LA Galaxy and Eisbaren Berlin; and Global Partnerships, which
oversees worldwide sales and servicing of sponsorships including naming rights, premium seating and
other strategic partnerships. Through its worldwide network of venues, portfolio of powerful sports and
Page 2 of 3
Parkhub, AEG Partner to Bring Game-Changing Parking Experience to Marquee Sports & Entertainment
Venues; Multiyear Agreement Names ParkHub the Official Parking ....
music brands, and its integrated entertainment districts, AEG entertains more than 160 million guests
annually. More information about AEG can be found at www.aegworldwide.com .
View source version on businesswire.com:

https://www.businesswire.com/news/home/20230411005126/en/
CONTACT: ParkHub
Brian Castle
919.360.9690
[email protected] BECK Media & Marketing for AEG Global Partnerships

Shannon Donnelly
310.300.4820
[email protected]
http://www.businesswire.com
Load-Date: April 11, 2023
End of Document
Page 3 of 3
Exhibit H
Reg. No. 5,680,286 AXS Group LLC (DELAWARE LIMITED LIABILITY COMPANY)
425 W. 11th Street, Suite 100
Registered Feb. 19, 2019 Los Angeles, CALIFORNIA 90015
CLASS 9: Audio and video recordings featuring recorded musical performances provided
Int. Cl.: 9, 41 through internet, video-on-demand, digital media and other forms of transmission media
Service Mark FIRST USE 9-7-2016; IN COMMERCE 9-7-2016
Principal Register CLASS 41: Entertainment services in the nature of a live performances, provided live and
through internet, video-on-demand, digital media and other forms of transmission media;
providing online information in the field of entertainment concerning performances by
musicians and bands; providing a website featuring non-downloadable audio recordings in the
field of musical performances provided through internet, video-on-demand, digital media and
other forms of transmission media
FIRST USE 9-7-2016; IN COMMERCE 9-7-2016
THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY

PARTICULAR FONT STYLE, SIZE OR COLOR
No claim is made to the exclusive right to use the following apart from the mark as shown:
"PATIO SESSIONS"
SER. NO. 88-024,582, FILED 07-03-2018

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION
WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE
DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.
Requirements in the First Ten Years*

What and When to File:
First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th
years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the
registration will continue in force for the remainder of the ten-year period, calculated from the registration
date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.
Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application
for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.
Requirements in Successive Ten-Year Periods*

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal
between every 9th and 10th-year period, calculated from the registration date.*
Grace Period Filings*
The above documents will be accepted as timely if filed within six months after the deadlines listed above with
the payment of an additional fee.
*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an

extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use
(or Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO).
The time periods for filing are based on the U.S. registration date (not the international registration date). The
deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for
nationally issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations
do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying
international registration at the International Bureau of the World Intellectual Property Organization, under
Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the
date of the international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the
international registration, see http://www.wipo.int/madrid/en/.
NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online at h
ttp://www.uspto.gov.
NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark
owners/holders who authorize e-mail communication and maintain a current e-mail address with the
USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark
Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms
available at http://www.uspto.gov.
Page: 2 of 2 / RN # 5680286
425 West 11th St., Suite 100
Registered Oct. 08, 2019 Los Angeles, CALIFORNIA 90015
CLASS 41: Arranging for ticket reservations for sporting events, musical concerts and other
Int. Cl.: 41 entertainment events; ticket agency services for sporting events, musical concerts and other
entertainment events, rendered online, through phone orders and through ticket outlets in
Service Mark various channels of distribution
Principal Register FIRST USE 11-30-2018; IN COMMERCE 11-30-2018

OWNER OF U.S. REG. NO. 4830497
SER. NO. 87-684,791, FILED 11-14-2017




Page: 2 of 2 / RN # 5880643
425 W. 11th St., Suite 100
Registered Jan. 07, 2020 Los Angeles, CALIFORNIA 90015
CLASS 35: Arranging and conducting business conferences in the field of ticketing and
Int. Cl.: 35 marketing of live sports and music events
Service Mark FIRST USE 5-15-2016; IN COMMERCE 5-15-2016
Principal Register THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY
SER. NO. 88-436,064, FILED 05-17-2019




Page: 2 of 2 / RN # 5953686
425 W. 11th St, Suite 100
Registered Jan. 07, 2020 425 W. 11th St., Suite 100
Los Angeles, CALIFORNIA 90292
Int. Cl.: 35 CLASS 35: Business research and data analysis services in the field of ticketing for live
sports and music events
Service Mark
FIRST USE 5-31-2019; IN COMMERCE 5-31-2019
Principal Register
No claim is made to the exclusive right to use the following apart from the mark as shown:
"INTELLIGENCE"
SER. NO. 88-472,621, FILED 06-13-2019




Page: 2 of 2 / RN # 5954081
Exhibit I
From: [email protected]
Sent: Tuesday, September 28, 2021 00:28 AM
To: [email protected]
Cc: [email protected]
Subject: Official USPTO Notice of Allowance: U.S. Trademark SN 90560832: FLASH SEATS: Docket/Reference No. AXS.018T
NOTICE OF ALLOWANCE (NOA)
ISSUE DATE: Sep 28, 2021
U.S. Serial Number: 90560832

Mark: FLASH SEATS
Docket/Reference Number: AXS.018T
No opposition was filed for this published application. The issue date of this NOA establishes the due date for the filing of a Statement of Use (SOU) or a Request
for Extension of Time to file a Statement of Use (Extension Request). WARNING: An SOU that meets all legal requirements must be filed before a registration
certificate can issue. Please read below for important information regarding the applicant's pending six (6) month deadline.
SIX (6)-MONTH DEADLINE: Applicant has six (6) MONTHS from the NOA issue date to file either:
- An SOU, if the applicant is using the mark in commerce (required even if the applicant was using the mark at the time of filing the application, if use basis was not
specified originally); OR
- An Extension Request, if the applicant is not yet using the mark in commerce. If an Extension Request is filed, a new request must be filed every six (6) months until the
SOU is filed. The applicant may file a total of five (5) extension requests. WARNING: An SOU may not be filed more than thirty-six (36) months from when the NOA
issued. The deadline for filing is always calculated from the issue date of the NOA.
How to file SOU and/or Extension Request:

Use the Trademark Electronic Application System (TEAS). Do NOT reply to this e-mail, as e-mailed filings will NOT be processed. Both the SOU and Extension Request have
many legal requirements, including fees and verified statements; therefore, please use the USPTO forms available online at https://www.uspto.gov/trademarks-application-
process/filing-online (under the "INTENT-TO-USE (ITU) FORMS" category) to avoid the possible omission of required information. If you have questions about this notice,
please contact the Trademark Assistance Center at 1-800-786-9199.
For information on how to (1) divide an application; (2) delete goods/services (or entire class) with a Section 1(b) basis; or (3) change filing basis, see
https://www.uspto.gov/trademarks-getting-started/process-overview/additional-information-post-notice-allowance-process.
FAILURE TO FILE A REQUIRED DOCUMENT OUTLINED ABOVE DURING THE APPROPRIATE TIME PERIOD WILL RESULT IN THE ABANDONMENT OF THIS
APPLICATION.
REVIEW APPLICATION INFORMATION FOR ACCURACY
If you believe this NOA should not have issued or correction of the information shown below is needed, you must submit a request to the Intent-to-Use Unit. Please use the
"Post-Publication Amendment" form under the "POST-APPROVAL/PUBLICATION/POST NOTICE OF ALLOWANCE (NOA) AMENDMENT FORMS" category, available at
https://www.uspto.gov/trademarks-application-process/filing-online/post-approvalpublicationpost-notice-allowance-noa. Do NOT reply to this e-mail, as e-mailed filings will NOT
be processed.
Serial Number: 90560832

Mark: FLASH SEATS
Docket/Reference Number: AXS.018T
Owner: AXS Group LLC
425 W. 11th St., Suite 100
Los Angeles , CALIFORNIA 90292
Correspondence Address: JONATHAN A. HYMAN
2040 MAIN STREET, 14TH FLOOR
IRVINE, CA 92614
This application has the following bases, but not necessarily for all listed goods/services:
Section 1(a): NO Section 1(b): YES Section 44(e): NO
GOODS/SERVICES BY INTERNATIONAL CLASS
035 - On-line ticket marketplace for sellers and buyers of tickets for sporting events, musical concerts and other entertainment events -- FIRST USE DATE: NONE; --
USE IN COMMERCE DATE: NONE
041 - Entertainment services, namely, ticket services in the nature of theatrical and entertainment ticket agency services; Online ticket services in the nature of
entertainment ticket agency services for entertainment, educational, sporting and cultural events; Entertainment ticket agency services; Online entertainment
ticket agency services; Ticket reservation and booking services for shows and sporting events; Provision of information relating to seating for shows; Providing
information relating to tickets for sporting events -- FIRST USE DATE: NONE; -- USE IN COMMERCE DATE: NONE
042 - Providing temporary use of on-line non-downloadable software for use in the sports and entertainment industries, namely, software for use in the issuance,
printing and exchange of event tickets; Providing temporary use of online, non-downloadable e-commerce software to allow users to conduct electronic
business transactions in online marketplaces via a global computer network; Providing online non-downloadable software featuring a search engine for or
searching and booking entertainment, education, sporting and cultural event tickets; Providing online non-downloadable software for accessing, reviewing and
purchasing tickets offers for sporting, musical, theatrical, entertainment, social, recreational and other cultural events; Computer service, namely, acting as an
application service provider in the field of information management to host computer application software for the purpose of providing users a search engine for
an aggregation of tickets on the secondary ticket market to sporting, musical, theatrical, entertainment, social, recreational and other cultural events; Application
service provider (ASP) featuring software for use by ticket sellers and venues in connection with the purchasing of tickets by patrons, managing ticket inventory,
managing communications with patrons; Providing temporary use of non-downloadable software for verification of event admission ticket validity and the
authentication of personal identification information; Providing temporary use of online, non-downloadable e-commerce software for purchasing tickets,
managing ticket inventory, managing communications, and reporting data and information regarding tickets; Application service provider (ASP) featuring
software for purchasing tickets, managing ticket inventory, managing communications, and reporting data and information regarding tickets; Providing on-line
non-downloadable software development kits (SDK) -- FIRST USE DATE: NONE; -- USE IN COMMERCE DATE: NONE
ALL OF THE GOODS/SERVICES IN EACH CLASS ARE LISTED.
Appropriate Specimens for Goods and/or Services: A trademark specimen should be a label, tag, or container for the goods, or a display associated with the goods. See
TMEP §§904.03 et seq. A service mark specimen should be an advertisement, sign, brochure, website printout or other image that shows the mark used in the actual sale or
advertising of the services. See TMEP §§1301.04 et seq. For an instructional video on what is an appropriate trademark or service mark specimen for a good and/or service,
click here.
Fraudulent statements may result in registration being cancelled: Applicants must ensure that statements made in filings to the USPTO are accurate, as inaccuracies may
result in the cancellation of any issued trademark registration. The lack of a bona fide intention to use the mark with ALL goods and/or services listed in an application or the
lack of actual use on all goods and/or services for which use is claimed could jeopardize the validity of the registration, possibly resulting in its cancellation.
Additional information: For information on filing and maintenance requirements for U.S. trademark applications and registrations and required fees, please consult the USPTO
website at https://www.uspto.gov or call the Trademark Assistance Center at 1-800-786-9199.
Checking status: To check the status of this application, go to

https://tsdr.uspto.gov/#caseNumber=90560832&caseSearchType=US_APPLICATION&caseType=SERIAL_NO&searchType=statusSearch or contact the Trademark
Assistance Center at 1-800-786-9199. Please check the status of any application at least every three (3) months after the application filing date.
To view this notice and other documents for this application on-line, go to
https://tsdr.uspto.gov/#caseNumber=90560832&caseSearchType=US_APPLICATION&caseType=SERIAL_NO&searchType=documentSearch. NOTE: This notice will only be
available on-line the next business day after receipt of this e-mail.
Exhibit J
Exhibit K
Exhibit L
Exhibit M
Exhibit N
Exhibit O
Case
7/26/23, 12:42 PM2:24-cv-00377-SPG-E Document
Event Tickets 1-15 Filed
Center, Inc. 01/16/24
| Reviews PageBureau®
| Better Business 2 of 10
ProfilePage ID #:152
Customer Reviews
Event Tickets Center, Inc.
Event Ticket Sales
View Business profile
391 Customer Reviews
Justin K
07/14/2023
They were super helpful accidently bought wrong tickets that didn't come with admission and
they helped with a promo code for what we spent to put towards actual tickets that's awesome I
give em 5 stars for that
Elan S
07/09/2023
This company is a scam! I thought I was purchasing tickets through ticket master and somehow
got redirected to event ticket center without knowing. I never received my tickets even though I
paid close to $300. I’ve contacted them multiple times and all they say is they will contact the
ticket seller. Nothing was resolved and I didn’t even get a refund. SCAM!!
Melissa A
07/08/2023
Sketchy and do not recommend- when you go to purchases tickets their site says no additional
fees- to which they throw on fees like delivery fee when we got will call tickets < > because
https://www.bbb.org/us/fl/gainesville/profile/event-ticket-sales/event-tickets-center-inc-0403-235973866/customer-reviews 1/9
Case
they’re a 3rd party seller and take your money for tickets they don’t even have. Total of close to
$100 fees were added to 2 tickets and the venue just told us that 3rd party sales are prohibited
so we are out a lot of money and very upset that we well overpaid for tickets that A) said no
added fees B) tickets aren’t guaranteed even though we paid for them. We are currently trying
to get a full refund from this company but have been unsuccessful thus far.
Jaylin B
07/06/2023
I accidentally bought tickets on the site after googling tickets for the drums and still haven’t
received my tickets nor can I get a refund. $140 later we will see.
KA K
07/06/2023
This company is a joke. Please buy tickets elsewhere. They told me they cannot guarantee 100
percent that we will get our tickets. Their prices are also much higher. They are simply a
platform to sell tickets on, unlike other sites that actually have the tickets. Buyer beware! We will
never use them again!!!
Kim M
07/05/2023
After purchasing 2 tickets online for 436.35 (including delivery and service fees). I downloaded
the tickets to find the face value of the tickets was 49.50 for each ticket. Their disclaimer reads:
prices MAY be above face value. This is totally inadequate... when it is stated that tickets may
be above face value, the implication is that they will be the same or slightly higher. The price
increase is astronomical - mine were 3 times the face value - 3 times! This type of price gouging
and providing ZERO transparency to the customer - only showing the real price of the ticket
AFTER the customer's purchase is processed- is unethical. When I complained they suggested I
try to resell the tickets. They offer the price they believe will give you the best chance of
reselling your tickets. If I had followed this advice I would get back approximately $200 - in the
end, I would have no tickets AND be out 236.35 (or so). No, thank you, These people are
unscrupulous and must be stopped. If you fall prey to these vultures, I encourage you to do
want I did and file a complaint with the FTC. These deceitful business practices are exactly why
the current administration is investigating Ticket Master. Event Ticket Centers could be next.
Pure, unadulterated greed.
Case
Matthew C
07/03/2023
This is a scam. They charged me $42 for a $14 ticket (direct from the venue), and finally offered
me a $6.30 refund. You search for tickets, they place ads at the top of the search results. If you
are in a hurry, they make it appear as if you are dealing directly with the event promoter. Really
fraudulent.
Event Tickets Center, Inc. Response 07/26/2023

We do not make anything look like customers are dealing directly with any promoter. On the
contrary, our website does not resemble any other and every page clearly states we are a
resale marketplace and ticket prices may be above face value.
Anne F
07/03/2023
This company is a scam. The trust pilot and other site reviews say enough altho the company
always responds to every user with, “This is not a scam.” Funny. They stole almost $900 from
my husband and I. Their phone customer service makes lies up about resending things and
refunds (I have recording as proof and dealing w this) and then they emailing you with some
other nonsense that was not the same as said on phone. Record all phone calls. Luckily we
booked Amex and they already refunded us for seeing this company scammed us. We
thankfully saved all e-mail proof, email recording or not tickets sent, and voice recordings of
phone calls claiming opposite of emails. I may have been scammed but at least my smarts
kicked in to record it all. One day this company I’ll have payback because they won’t stay in
business long. I’ll be part of making sure that happens. Buyer beware. You won’t get tickets
through this company or will get some kind of scam from them. Not worth any chance at a
ticket.
Linda H
07/03/2023
I just paid $218 for tickets ($109 each) for 2 VIP tickets to see Ali Siddiq at the Improv in Ontario.
I was also charged $65.50 service fee, and $9.95 for a delivery fee when the tickets will be
emailed to me. When I called a friend and told her about the concert she decided to go and
called the box office to the venue and paid only $38 each for three tickets plus a small service
fee. I haven’t bought a ticket to a concert in years, was ecstatic about seeing Ali live and didn’t
think it far fetched to pay $109 for VIP tickets. Further insult to injury, after the payment was
Case
charged to my card, the receipt had a disclaimer stating that the seller (Event Tickets Center)
stated: “There is a 2 item per person minimum purchase requirement of food or beverage
items;”, “that the tickets may be in the specific section or in an equivalent or better location.”
Then it says:: “ this listing describes tickets that the seller does not own, or may not know the
exact location of the seats, but is offering to obtain for you. Once your order is confirmed, we
guarantee that you will receive tickets prior to the start of the event receipts that are in the
equivalent or better locator are you will receive a full refund.“ How can they guarantee that I will
receive seats that are in an equivalent or better location if they don’t on the tickets? I really am
looking forward to seeing Ali but I am quite disappointed and feeling like I have been robbed
by this agency based on the fact that I have over triple as my friend had to pay because I use
this agency. The moral of the story is whenever you buy tickets from anywhere we say, and
purchase them from the venue where the event is going to be held, and not from this window
mean over pricing agencies that will gouge you. I’ve learned my lesson and of I have any
problem with the seating at the concert when I go on July 16, I will be making another review to
let you know turned out.
John W
07/01/2023
What an absolute rip off, please be careful. They do not offer refunds and their customer
service sucks. I wanted to take my family to an event, they quadruple charged me. This site is
very fraudulent. I hope this company and all their employees who know what they doing get the
karma they deserve. Avoid at all costs.
Paula H
06/29/2023
Like others have opined, I felt tricked by this website's pop up tactic, as I was not searching for
a ticket "resale" opportunity. I started out my ticket search on Ticketmaster and somehow
ended up buying from Event Tickets Center. The show I'd purchased tickets for was
rescheduled and although I received emails pretending to send me the tickets I had spent over
$1,000 USD on, there were never any tickets. The customer service number for Events Tickets
Center is all a facade. The number did not go through to anything except a hang up. I had
bought insurance and attempted to utilize that -- and it was the same thing -- it just hangs up on
you without even pretending to be legitimate, really. Do not buy tickets from these scam artists.
Jessica O
06/28/2023
So when you “buy a ticket”, you are actually paying a reseller, who has not bought a ticket yet,
to buy one for you. Basically, you’re not even buying a ticket.
Case
Erika T
06/26/2023
This business is up charging x3 and adding a $75 service fee! They also are saying that tickets
are limited when they are not. I live in Austin, Tx and made the mistake of using them when I
was in a hurry on my lunch break, then came to my senses and was like wow I can’t believe
tickets were so expensive to an up and coming musician, but when Taylor swift and others are
300-500, I was like maybe inflation? Then I go to Molly Burch’s website (where the business
bought them from) and they are $22 each and plenty of tix available. I should have done my
research more, but to me this is BAD business. I get trying to make a buck, but 3x the
amount!!!Taking advantage is not cool! I hope they get shut down. I certainly will not give them
MY business again. Buyer BEWARE!!’

We are a resale marketplace where sellers list their tickets. We do not set prices nor monitor
pricing and availability from other sources. I will have customer service reach out and see if
they can help.
Nanci W
06/24/2023
In my mind this site is fraud. I went through the options twice and only after I completed my
transaction did I comprehend that there is no ticket at this time and I would be pay more than
double the price on the Seattle Opera page, just to receive a ticket at a time more than a month
away, just prior to the date. Many tickets were available at the opera at much lower prices.
What, I wonder is the value add. Just a trap.

We are a resale marketplace where sellers list their tickets. We do not set prices nor monitor
pricing and availability from other sources. The website makes it very clear that we are a resale
marketplace and ticket prices may be above face value. I will have customer service reach out
to see if they can help.
Case
Stephen H
06/24/2023
Purchased tickets to event. They said delivery occurred. Their “proof” is an email that says you
should receive another email with tickets. Other email never came. Contacted customer service
(as noted in instructions) 4 times at concert. They would not resolve issue. All emails, log-one
etc were checked and double checked while on phone. No tickets. Left venue after never
receiving tickets or callback from a manger. They said that would not refund because they have
“proof” of delivery. Which again is an email that says “look for another email”. DO NOT USE this
service. Cost me $450 for the pleasure of making phone calls about emails I never received.
Cheri P
06/22/2023
Very bad customer service and shadywrbsite which doesn't allow any refund in whatsoever
circumstances.

The website is very transparent that we are a resale marketplace and all sales are final. This
customer filed a chargeback and their financial institution investigated and closed it in the
merchants favor. Not shady about the website.
Jess H
06/22/2023
Buying tickets via Ticket Event Centre was easy and I had no issues. At first I was worried
because it said my tickets wouldn’t be sent til the day before the concert…in September. But I
actually got them less than 12 hours later! They’re the same price as any other website. No
more gouging than ******* or ************. People have left some bad reviews, but I had no issues
and was completely satisfied! Don’t worry needlessly that you’ve been scammed. As far as I’m
concerned they’re legit!
Tracey G
06/21/2023
Case
This company advertised directly on a local event website that I frequent. Their ad made it look
like they were the direct/official vendor for the concert I was purchasing tickets for. Upon going
to check out, they listed the costs at the top of the check out page and buried at the bottom of
the page in an area that required an additional click through they posted the actual total. They
were selling event tickets for DOUBLE the actual cost, and added processing fees that totaled
in half the price of each ticket. This event was not sold out and is a sweet, local concert series
and was not sold out, tickets easily available directly. It's such a bummer that companies
choose to make money in this way. Such an lame way to do business and make money in a
world where there are abundant ways to do good in this world.
Travis W
06/19/2023
Def scam I would never recommend any one buying tickets from here. They charge you double
then also charge you $9.99 delivery fee for digital tickets and $20 in taxes and $50 in
processing fees. I was def scammed when purchasing these tickets. Shame on me for not
checking more into other places in pricing before purchasing. I will make sure never to
purchase tickets from here again. I wish I would of looked at these rating before buying.

No one was scammed. We are a resale marketplace where sellers list their tickets. We clearly
state at the top of every page that ticket prices may be above face value. This was very clear
before the person decide purchase. And of course people have to pay taxes when they are
due. I will have customer service reach out to see if they can help.
Tammy I
06/19/2023
We googled Matt Rife tickets. Took us to event tickets website. Showing tickets. Made our
selection and paid. When we received the email it showed Mike Epps was the show we
purchased. I immediately called them told them what happened. All I got was to bad. Asked to
speak to a manager and was told there was no one available. The only thing they could help
with was to re list them and hope they get sold. If I could give them a zero I would.
Case
This customer entered the website via a ****** search of "***************** tickets" They landed on a
***************** page. Then they proceeded to a number of events and performer page before
selecting and purchasing 2 order of ***************** tickets. The correct ***************** tickets were
delivered by the sellers for both orders.
Customer Review Rating
1.15/5
Average of 391 Customer Reviews
Contact Information
308 W University Ave Ste B
Gainesville, FL 32601-5208
Visit Website
(866) 820-4553
BBB Rating & Accreditation
A+
Accredited Since: 12/16/2021
BBB Business Profiles may not be reproduced for sales or promotional purposes.
Years in Business: 24
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publish complaints, reviews and/or responses on this website to affirm that the information provided is accurate. However,
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7/26/23, Case
12:42 PM2:24-cv-00377-SPG-E Document
Event Tickets1-15 Filed
Profile Page ID #:160
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Case 2:24-cv-00377-SPG-E Document 1 Filed 01/16/24 Page 1 of 46 Page ID #:1

1 DORSEY & WHITNEY LLP

1 AXS tickets, distributed by Defendants through unaffiliated websites or emails are

1 wanton and oppressive conduct.

1 Verified-Ticket.com and the contact information provided is a proxy called “Contact

1 AXS Mobile ID Technology (Formerly Known as “Flash

1 5,954,081 AXS 35: Business research and data analysis services in

1 Certificates of Registration are collectively referred to herein as the “AXS App

1 AXS Terms of Use, Permitted Use of Mobile Application,

21 damages and harm to Plaintiff’s reputation. It is causing and is likely to cause

1 LLC. “axs.amosa.app” is a “subdomain” where “axs” was added by the individual

1 Plaintiff’s authority or consent.

1 elements of the AXS App.

1 malicious, and in bad faith.

1 either actual damages, or statutory damages as provided for pursuant to 17 U.S.C.

Enter Domain or IP WHOIS

veri ed-tickets.com Updated 27 days ago

Domain: veri ed-tickets.com

Expires On: 2023-09-15

Updated On: 2022-09-15

Status: clientTransferProhibited On Sale!

Name Servers: ns1.a2hosting.com

Registrant Contact .PRO @ $3.88 $28.88

Name: Contact Privacy Inc. Customer 7151571251

Organization: Contact Privacy Inc. Customer 7151571251

Street: 96 Mowat Ave

Postal Code: M4K 3K1

Email: https://domains.google.com/contactregistrant?domain=veri ed-

Name: Contact Privacy Inc. Customer 7151571251

Organization: Contact Privacy Inc. Customer 7151571251

Street: 96 Mowat Ave

Postal Code: M4K 3K1

Email: https://domains.google.com/contactregistrant?domain=veri ed-

Name: Contact Privacy Inc. Customer 7151571251

Organization: Contact Privacy Inc. Customer 7151571251

Street: 96 Mowat Ave

Postal Code: M4K 3K1

Email: https://domains.google.com/contactregistrant?domain=veri ed-

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Registry Domain ID: D319751176-CNIC

Updated: 2023-09-14 07:58:25 UTC

Created: 2022-08-26 17:48:21 UTC

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Organization: Privacy service provided by Withheld for Privacy ehf

Mailing Address: Kalkofnsvegur 2, Reykjavik, Capital Region, 101, IS

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