VIA CERTIFIED MAIL – RETURN RECEIPT REQUESTED
Eventbrite, Inc.
Attn: Legal Department,
95 Third Street, 2nd Floor,
San Francisco, California, 94103
Re: Pre-Arbitration Notice of Individual Consumer Privacy Dispute
To Whom It May Concern:
I am sending this Notice of Dispute to notify Eventbrite, Inc., together with its subsidiaries, affiliates, agents, and related entities (collectively, “Eventbrite”), of my individual dispute arising from my use of Eventbrite’s services and Eventbrite’s deployment or enablement of third-party tracking code and related technologies in connection with, and during, my electronic communications and interactions with Eventbrite.
Nature and Basis of the Dispute
I used Eventbrite’s services while physically located in {answer_2}. During my use of those services, I {answer_3} and otherwise communicated and interacted with Eventbrite. To the best of my recollection, this use occurred within the applicable limitations period.
Based on my current understanding and counsel’s investigation into Eventbrite’s tracking practices, Eventbrite deployed, enabled, or caused the deployment of tracking code associated with Meta/Facebook and TikTok, including on eventbrite.com. That investigation showed that the tracking code caused or permitted the contents of electronic communications with Eventbrite, or information reflecting the substance and meaning of those communications, to be contemporaneously transmitted or otherwise made available to Meta, TikTok, or other third parties. Depending on the interaction, the information transmitted or made available included or reflected search terms, events or content searched for or viewed, selections made, and other substantive event-, ticket-, account-, or transaction-related activity. For example, search terms entered through Eventbrite’s search functionality were included in page URLs transmitted to both Meta and TikTok, and event names and dates reflected in event-page titles were transmitted to Meta. The investigation also observed TikTok’s `_ttp` cookie being set on the initial page load of eventbrite.com. Taken together, these findings support a reasonable inference that Eventbrite deployed or enabled the challenged tracking code not merely to process communications between consumers and Eventbrite, but to associate information reflecting the contents or substance of those communications with consumer identifiers or persistent behavioral profiles and to facilitate the subsequent profiling, use, disclosure, targeted advertising, marketing, commercial exploitation, or other unlawful downstream use of that information.
Upon information and belief, the challenged tracking code operated in the manner described above in connection with my electronic communications and interactions with Eventbrite, causing or permitting the contents or substance of my communications to be contemporaneously transmitted or otherwise made available to Meta, TikTok, or other third parties.
I did not provide legally sufficient prior consent or authorization for Meta, TikTok, or another unrelated third party to contemporaneously receive, read, learn, or otherwise acquire the contents of my electronic communications with Eventbrite as described above.
Separately, the investigation showed that the challenged tracking code and related technology recorded or decoded non-content dialing, routing, addressing, signaling, or related information associated with electronic communications and interactions with Eventbrite. This information included or reflected, as applicable, IP addresses and browser-, device-, cookie-, session-, request-, or other identifiers associated with the source, destination, routing, addressing, or transmission of those communications. Upon information and belief, the challenged tracking technology operated in this manner in connection with my electronic communications and interactions with Eventbrite, thereby recording or decoding non-content dialing, routing, addressing, signaling, or related information associated with my communications.
I contend that the conduct described above violated applicable federal and state anti-wiretapping, interception, eavesdropping, and electronic-surveillance laws, including the federal Wiretap Act, as amended by the Electronic Communications Privacy Act of 1986, 18 U.S.C. §§ 2510–2523, including 18 U.S.C. § 2511, by intentionally intercepting, endeavoring to intercept, procuring, enabling, or otherwise causing the interception of my electronic communications in violation of federal law. These claims include any applicable theories concerning interception, procurement or assistance of interception, and use or disclosure of unlawfully intercepted communications recognized under the law governing my communications.
I further contend that Eventbrite violated California Penal Code §§ 638.50–638.51 by installing, using, enabling, or causing the use of a pen-register device or process that recorded or decoded non-content dialing, routing, addressing, signaling, or related information associated with my electronic communications, without first obtaining the required court order and without any applicable statutory exception or other lawful authorization.
I reserve all other statutory, common-law, contractual, consumer-protection, privacy, equitable, or related claims, theories, rights, and remedies supported by the facts and applicable law.
Relief Sought
I presently seek $5,000 in monetary relief to resolve this dispute. This amount reflects my present good-faith settlement demand based on the information currently available, including the claims asserted and the remedies potentially available under the federal Wiretap Act, applicable state anti-wiretapping, interception, eavesdropping, and electronic-surveillance laws, and other applicable law. I also seek injunctive relief requiring Eventbrite to cease the challenged tracking practices unless and until Eventbrite brings those practices into compliance with applicable law.
Nothing in this Notice waives any claim, remedy, or right to seek different or additional relief if subsequently discovered facts, applicable law, or the course of proceedings establishes entitlement to such relief. Nor does this Notice constitute any concession concerning the number, measure, or proper unit of violations or damages.
Eventbrite should take reasonable steps to preserve documents and electronically stored information relevant to this dispute, including information concerning the challenged tracking technologies, their configuration and operation, my relevant interactions with the Eventbrite Services, and the information collected, recorded, or transmitted in connection with those interactions. This request extends to relevant information within Eventbrite’s possession, custody, or control, including information maintained by vendors or service providers to the extent within Eventbrite’s control. Eventbrite should take reasonable steps to prevent the routine deletion, overwriting, or destruction of such relevant information.
Informal Resolution
I am providing this Notice in good faith to afford Eventbrite an opportunity to resolve this dispute before formal proceedings become necessary. I am willing to engage in good-faith resolution discussions during the 60 days following Eventbrite’s receipt of this Notice. If the dispute is not resolved, I am prepared to pursue arbitration before the American Arbitration Association and pursue any other available remedy. See Eventbrite, Terms of Service https://www.eventbrite.com/corporate/legal/legalterms/ (last visited August 2026).
Nothing in this Notice constitutes a concession or waiver concerning the existence, formation, assent to, notice of, applicable version, applicability, scope, interpretation, or enforceability of any arbitration, dispute-resolution, or related procedural provision Eventbrite may invoke, including any procedures or conditions governing the initiation, administration, or resolution of a dispute. Nothing in this Notice constitutes assent to or acceptance of any amendment, modification, or different version of Eventbrite’s terms that Eventbrite may contend governs this dispute. I further reserve all arguments that any purported requirement has been satisfied or substantially complied with, waived or forfeited, excused, inapplicable, or unenforceable. Nothing in this Notice waives any claim, remedy, defense, objection, or right to proceed in any forum otherwise available under applicable law.
This Notice is based on the information currently available and is not intended as an exhaustive statement of all facts, claims, theories, or remedies. I reserve the right to supplement this Notice as additional information becomes available.
If Eventbrite considers this Notice deficient in any manner, please notify my attorneys so that counsel may consider and respond during the informal-resolution process.
I authorize Eventbrite to communicate with my counsel identified below and to produce to them all records and information associated with me that are reasonably necessary to evaluate and resolve this dispute.
Please direct all communications concerning this matter to my counsel identified below.
Sincerely,