Rubinstein v. Vivid Seats Inc.

CourtDistrict Court, E.D. New York
DecidedSeptember 29, 2025
Docket2:24-cv-01387
StatusUnknown

This text of Rubinstein v. Vivid Seats Inc. (Rubinstein v. Vivid Seats Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rubinstein v. Vivid Seats Inc., (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -------------------------------------------------------x JANINE RUBINSTEIN, individually and on behalf of all others similarly situated,

Plaintiff, MEMORANDUM & ORDER 24-CV-1387 (PKC) (AYS) - against -

VIVID SEATS INC.,

Defendant. -------------------------------------------------------x PAMELA K. CHEN, United States District Judge: Plaintiff Janine Rubinstein (“Plaintiff” or “Rubinstein”) filed her Class Action Complaint (“Complaint”) in this district against Vivid Seats, LLC (“Defendant” or “Vivid Seats”) on February 25, 2024, alleging violations of New York’s Arts and Cultural Affairs Law (“ACAL”) § 25.07(4). (Compl., Dkt. 1, ¶ 1.) On July 1, 2024, Plaintiff filed a Consolidated Class Action Complaint (“Consolidated Complaint”). (Consolidated (“Cons.”) Compl., Dkt. 20.) Plaintiff brings this action on behalf of herself and all others similarly situated (“Putative Plaintiffs”).1 (Id. at 1.) Currently before the Court are Defendant’s motions to compel arbitration and dismiss the Consolidated Complaint for lack of jurisdiction and failure to state a claim. (Def.’s Mot. to Compel Arbitration and Mot. to Dismiss (“Mot.”), Dkt. 28.) For the reasons stated below, the Court grants Defendant’s motion to compel arbitration, defers ruling on Defendant’s motion to dismiss for lack of jurisdiction and failure to state a claim, and stays this action pending arbitration.

1 No class has been certified. BACKGROUND I. Factual Background2 The Putative Plaintiffs are New York individuals who purchased tickets to an event through Defendant’s website, https://www.vividseats.com/ (the “Website”). (See Cons. Compl., Dkt. 20, ¶¶ 39–40.) Defendant is a Delaware limited liability company with its principal place of business in Chicago, Illinois. (Id. ¶ 11.) Defendant owns and operates the Website. (Id.)

A. Defendant’s Website Individuals can purchase tickets to a range of events through the Website. (Id. ¶¶ 7–10 (discussing the nature of the events for which Putative Plaintiffs purchased tickets).) “When a prospective purchaser visits [the Website] to purchase a ticket to an event, they are initially prompted with ticket seating options and a corresponding price for each ticket.” (Id. ¶ 17.) “The price shown at this stage of the purchase process makes no mention of any fees.” (Id. ¶ 18.) “[A]fter purchasers make a seating selection, they are presented with a higher ticket price than originally shown, along with an added notation in fine print indicating an added fee,” with “[n]o further details regarding the nature of the fee.” (Id. ¶ 19.) Finally, after making a seat selection, “purchasers reach the order summary page where . . . for the first time in the multi-step purchase

process, the purchaser is made aware that the added fee presented . . . is a ‘Service’ fee.” (Id. ¶ 20.) The Website “offers no explanation of what the ‘Service’ fee is or what is provided to purchasers for paying this fee.” (Id.)

2 The Court takes the following from “all relevant, admissible evidence submitted by the parties” and “draw[s] all reasonable inferences in favor of the non-moving party.” Meyer v. Uber Techs., Inc., 868 F.3d 66, 74 (2d Cir. 2017) (internal quotation marks and citations omitted). B. Plaintiff's Ticket Purchase Plaintiff made the purchase at issue on the Website on August 2, 2023, when she bought eight tickets to a New York Mets baseball game. (Cons. Compl., Dkt. 20, 7.) Plaintiff proposes a class of Putative Plaintiffs who are “[p]urchasers of tickets through Defendant’s [Website] who were subjected to a ticket sales process which violated ACAL.” (d. § 38.) C. The Website’s Terms of Use When purchasing tickets on the Website as of the date of Plaintiffs purchase, all purchasers were required to click a pink button on the purchase page (“Purchase Page”) of the Website that read “Place Order,” as shown below: Confirm and Place Order condivons and confirm thet you are aware that you may be paying above face vlue for your ticket, Your cred

(Bakal Decl., Dkt. 29-1, § 4.) The Purchase Page had a white background. (Def.’s Mem. Supp. Mot. (“Mem.”), Dkt. 29, at 13.) Against this white background and directly above the pink “Place Order” button, the following message instructed the purchaser: “By clicking ‘Place order[,’] you agree to the Vivid Seats terms of use.” (Bakal Decl., Dkt. 29-1, § 4.) “The phrase ‘terms of use’ appeared in the same pink color as the ‘Place Order’ button, and the phrase was hyperlinked to the terms of use... then in effect [((“TOU”)], so that the [TOU] would open in the customer’s internet browser upon clicking on the phrase ‘terms of use.’” (/d.) The Website design “did not allow [Plaintiff] to complete her August 2, 2023 ticket purchase unless she first clicked the ‘Place Order’ button directly below the message stating that, ‘[b]y clicking “Place Order[,”] you agree to the Vivid Seats terms of use’ with a hyperlink to the [TOU].” (Ud. ¥ 5.)

The TOU included several provisions relevant to Defendant’s motion to compel arbitration. First, at the top of the TOU in capital, bolded letters was a provision notifying purchasers that the TOU “contain an arbitration and dispute resolution provision that requires you and [Defendant] to resolve disputes . . . by binding and exclusive arbitration instead of in a court or before a jury, unless you choose to timely opt out.” (Id. at ¶ 6 (quoting TOU, Dkt. 29-1, at ECF3 7).) Second,

in the same paragraph at the top of the TOU, it states: “In arbitration, a class, representative, or consolidated action or proceeding will not be permitted.” (Id.) There is no evidence that Plaintiff has opted out of the arbitration and dispute resolution provision. D. The ACAL Pursuant to the ACAL, Every operator or operator’s agent of a place of entertainment, any licensee or other ticket reseller, or platform that facilitates the sale or resale of tickets shall disclose the total cost of the ticket, inclusive of all ancillary fees that must be paid in order to purchase the ticket, and disclose in a clear and conspicuous manner the portion of the ticket price stated in dollars that represents a service charge, or any other fee or surcharge to the purchaser. Such disclosure of the total cost and fees shall be displayed in the ticket listing prior to the ticket being selected for purchase.

N.Y. Arts & Cult. Aff. Law § 25.07(4). “Defendant is a ‘platform that facilitates the sale or resale of tickets.’” (Cons. Compl., Dkt. 20, ¶ 54 (quoting id.).) Therefore, Plaintiff alleges, “Defendant had a statutory obligation to ‘disclose the total cost of the ticket, inclusive of all ancillary fees that must be paid in order to purchase the ticket, and disclose in a clear and conspicuous manner the portion of the ticket price stated in dollars that represents a service charge, or any other fee or surcharge to the purchaser’ at the first point that ticket prices are displayed on their website.” (Id. ¶ 55 (quoting same).) Plaintiff highlights that, pursuant to the New York Division of Licensing

3 Citations to “ECF” refer to the pagination generated by the Court’s CM/ECF docketing system and not the document’s internal pagination. Services, “the ticket purchasing process begin[s] once a consumer visits a ticket marketplace and first sees a list of seat prices.” (Pl.’s Opp’n to Mot. (“Opp’n”), Dkt. 31, at 2 (quoting N.Y. State Div. of Licensing Servs. (Oct. 24, 2022)4) (altered to match original).) “From the moment the prospective purchaser assesses the . . . ticket lists . . .[,] there should be no price increases to the

purchaser for the ticket itself.” (Id.

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Rubinstein v. Vivid Seats Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/rubinstein-v-vivid-seats-inc-nyed-2025.