When a Beyoncé stadium show sells out in minutes, fans have long suspected that someone other than fans got there first. A federal lawsuit filed Thursday in San Diego names one of those someones — and lays out, in rare detail, how a modern ticket broker allegedly turns a four-ticket limit into a 7,624-ticket haul.
The U.S. Department of Justice, acting on a referral from the Federal Trade Commission, sued San Diego-based broker REPS & Company and three of its top executives on Oct. 15, accusing them of violating the Better Online Ticket Sales (BOTS) Act and the FTC Act. REPS is a member of the National Association of Ticket Brokers and the 22-page complaint alleges that between January 2022 and October 2025, REPS exceeded the eight-ticket purchase limit from Ticketmaster and AXS for at least 83,000 separate events. The lawsuit alleges that REPS spent over $1.3 billion to amass more than 18.5 million tickets, then resold them on StubHub, Vivid Seats, SeatGeek, Gametime, TicketNetwork and Ticketmaster's own resale marketplace for at least $120.8 million in profit.
The headline numbers are staggering. But the real value of the complaint is the operating manual buried inside it: power-of-attorney agreements used to mint accounts, SIM banks catching verification codes, a purchasing floor in the Philippines running 15 browser tabs at a time, and an internal "Error Bible" for beating Ticketmaster's limit errors. What follows is that playbook, as the government describes it. None of the allegations have been tested in court, and REPS has not yet filed a response.
The company and the men who run it
REPS & Company, Inc. is a California corporation headquartered at 4141 Jutland Drive in San Diego's Clairemont area. The complaint describes it plainly as a ticket broker: it buys from primary ticket issuers and resells on the secondary market at a higher price. According to the suit, REPS was formed in 2017 — about a year after Congress passed the BOTS Act.
Three executives are named individually, which matters because it exposes them to personal liability:
Ryan Pancheri, CEO. The government says he supervises everything from technology and data analytics to purchasing, pricing, fulfillment and HR, manages how REPS identifies buying opportunities, and has personally bought tickets on the company's behalf.
Brian Archibald, President (formerly COO). He oversees what REPS internally calls its "brokerage" — the process of deciding which tickets to buy. The complaint says he also monitors resale-industry news and participates in industry groups. Archibald is the former CEO of broker Barry’s Tickets and an adjunct professor at St Marys College in Northern California.
Nicholas Totagrande, COO. He runs ticket operations: purchasing, listing for resale and distribution. He is the only defendant the complaint says lives in the Southern District of California, and he appears most often in the internal communications the government quotes.
The complaint also name-checks Broker Genius Inc., which does business as Automatiq, a widely used broker software vendor. Automatiq is not a defendant, but the government says REPS used it to fully automate the creation of hundreds of ticketing accounts, as well as to integrate with marketplaces like Vivid Seats and list tickets automatically.
Step one: pick the shows that will flip
REPS doesn't buy everything. The complaint says its model depends on identifying events where demand will outstrip supply and resale prices will clear face value — then buying before ordinary fans can. To do that, the company allegedly uses analytics software and data scraping to track artist popularity and tour routing, and watches secondary-market trends to predict which shows will sell out and which seats will be most profitable.
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