Comment Text:
April 30, 2026
Christopher Kirkpatrick
Secretary of the Commision
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581
Dear Mr. Kirkpatrick,
I am writing in my capacity as Chief Financial Officer of Great Buy Tickets to express support for the continued development of a clear and practical regulatory framework for sports prediction markets in the United States.
Great Buy Tickets operates as a large ticket broker, managing inventory across a wide range of live sporting events. Our business is directly exposed to the outcomes of those events. Team performance, playoff advancement, and individual player storylines all have a meaningful impact on ticket demand, pricing, and liquidity in both primary and secondary markets.
We are often required to take positions on ticket inventory well in advance of knowing how a season or matchup will unfold. When a team exceeds expectations or advances deeper into the postseason, demand and prices can rise quickly. Conversely, when outcomes fall short of expectations, we can be left holding inventory that declines in value. These dynamics create real financial exposure tied to uncertain future events.
We are actively evaluating how sports prediction markets could be used as a risk management tool alongside our existing analytics. Market-implied probabilities around game outcomes, playoff advancement, and related events could help inform our inventory strategy. More importantly, these markets may allow us to take offsetting financial positions that help hedge downside risk associated with inventory we hold.
For example, if we build a position in tickets tied to a team’s potential playoff run, a corresponding position in a prediction market could help balance that exposure in the event outcomes do not materialize as expected. This type of approach would allow us to operate with greater confidence, improve pricing discipline, and ultimately create a more stable market for consumers.
We view sports prediction markets as a practical extension of existing risk management tools used across other industries. With appropriate safeguards in place, including strong standards for market integrity and consumer protection, they can serve legitimate commercial purposes and improve how companies like ours manage uncertainty.
We encourage the Commission to support a framework that allows for responsible innovation in this area.
Thank you for your time and consideration.
Sincerely,
Shawn Lameh
Chief Financial Officer
Great Buy Tickets
