Tuesday, January 26, 2021 Last week marked a double milestone for the FTC: Rebecca Slaughter assumed the role of Acting Chair, and the agency brought its first enforcement action under the Better Online Ticket Sales Act (“BOTS Act”), 15 U.S.C. § 45c(a)(1). Enacted in 2016 but somewhat dormant until now, the BOTS Act entitles the FTC to proceed against any person who “circumvent[s] a security measure, access control system, or other technological control or measure on an Internet website or online service that is used by the ticket issuer to enforce posted event ticket limits or to maintain the integrity of posted online ticket purchasing rules.” The statute is meant to address ticket resellers using programs or other pieces of technology—like bots—to instantly buy up hundreds or thousands of tickets to a concert or game as soon as they go on sale, only to sell them again at a massive upcharge.