55 University Ave., Suite 600
Toronto ON M5J 2H7
David Sterns
Phone: (416) 977-5229
Email: dsterns@sotos.ca April 10, 2026 Assistant: Georgia Scott-McLaren
The Honourable Justice Denis Gascon c/o Competition Tribunal 17 th Floor, 333 Laurier Avenue West Ottawa, Ontario K1A 0G7
Phone: Email:
(416) 977-5333 ext. 310 gscott-mclaren@sotos.ca
File No: 30245
Dear Justice Gascon:
Re: Consumers Council of Canada v. Live Nation Entertainment, Inc. et al., CT-2025-008
We write to you in response to the letter dated March 27, 2026 from the respondents in the above-mentioned case requesting permission to file the proposed affidavit of Patti-Anne Tarlton (“Tarlton Affidavit”).
The Tarlton Affidavit is focused on showing that the respondents do not have control over many live music venues in Canada. Viewed on its own, the Tarlton Affidavit paints an incomplete or misleading picture. For example, it lists venues that the respondents do not “own or operate,” but it fails to mention that many of those same venues are exclusively ticketed by the respondent, Ticketmaster. We have enclosed a brief draft reply affidavit of Maria Arabella Robles (“Robles Reply Affidavit”), which identifies venues referenced in the Tarlton Affidavit over which the respondents appear to have substantial ticketing control.
The applicant consents to the filing of the Tarlton Affidavit – assuming it is not materially changed before it is sworn and filed – if the Robles Reply Affidavit can also be filed.
All of which is respectfully submitted.
Yours truly, SOTOS LLP
David Sterns
c. Adil Abdulla (aabdulla@sotos.ca) and Maria Robles (mrobles@sotos.ca), co-counsel for the applicant Linda Plumpton (lplumpton@torys.com), James Gotowiec (jgotowiec@torys.com), Collette Koopman (ckoopman@torys.com), and Martha Côté (mcote@torys.com), counsel for the respondents
Sotos Class Actions is a practice group of Sotos LLP