Buying Tickets: 2010 ADA Ticketing Regulations and You

Operator

Good day ladies and gentlemen and welcome to the Buying Ticket: ADA Ticketing Regulation and You conference call. At this time, all participants are in listen only mode. Later we''ll conduct the question and answer session and instructions will be given at that time. If anyone should require assistance during the conference, please press star then zero. As a reminder, this conference is being recorded. I would now like to turn the call over to your host, Robin Jones. You may begin.

Robin Jones

Thank you and good morning and good afternoon to all of you as you are joining us from different parts of the country. I want to welcome you to the ADA Audio Conference Series which is sponsored by the ADA National Network. This is one of our programs that we offer, covering various topics from the Americans with Disabilities Act. As you heard from the operator, today''s session is going to be focusing on the ticketing regulation. Our focus today will be primarily looking at how does this really affect the individual and what their needs are or what they need to know about the changes that have taken place under the revisions to the Department of Justice regulation specifically related to the ticketing industry at a variety of different venues, whether it be sports or arts or other areas where you might purchase tickets to participate. We have two wonderful speakers today and before I introduce them, I just want to go over a few of the logistics of the program. We have people started speaking today in a variety of different methods and modes. We have individuals who are participating fully by telephone and listening to us as we talk today. There are individuals who are also joining us by what we call streaming audio on the internet and now we also have individuals who are using the online webinar platform to view the slides and follow along with us today. Each of these actions provides different ways for people to ask questions. Those of you who are on the telephone and would wish to ask the question via the telephone, our operator, when we''re ready to take questions, will direct you on how to do that. Those of you that are participating by streaming audio on the internet, you will use the interface that''s available to you on that system to submit your question. And for those who are on the webinar platform which also includes individuals who are using captioning today can submit your questions either by telephone if you are connected to the telephone and/or you can submit them by the chat room that is available to you in the webinar platform. We''ll be monitoring all of these ways to take your questions and so we will be feeding those to our speakers today. This session is being recorded and it will be available on as an archive, both a written archive as well as an audio archive within 10 days at the end session which gives us time to edit the current script and such and get it up on to the ada-audio.org website. So, before I waste too much time in this session today, I want to go ahead and just introduce our speakers and then I will be turning over to them to deliver the content today. First we have Kleo King who is a Senior Vice President of Accessibility Services at United Spinal Association. Kleo worked for a long time in the field of disability as a legal adviser and attorney primarily in the areas of housing, air transportation and access to public cases. She''s also active in the regulatory process involving the rights of people with disability. She has served with the American Bar Association on different programs that they have to offer. She''s been a member of the New York City Bar Association Committee on Legal Issues Affecting People with Disabilities and she was also a member of the United States Access Board''s Courthouse Advisory Committee. Some of the assignments that she''s working on and has been assigned to within United Spinal Association is developing ticket policies for accessible seating with numerous professional sports team, and entertainment venues; ensuring that new venues comply with the Americans with Disabilities Act and local building code requirements, including the Jazz Center--Jazz at Lincoln Center, Citi Field, the New York Yankee Stadium, and the target Field. She also worked with PepsiCo reviewing their facilities for usability for people with disabilities. She has a lot of very extensive experience and has worked again on housing and other areas as well. Our second speaker is Betty Siegel and she is Manager of Accessibilities with the John F. Kennedy Center for the Performing Arts in Washington DC. She has specialized in arts and disability issues for over 25 years and she started in the field at various stages in Washington DC, moved to Austin, Texas where she ran a small arts and disability non-profit and was certified as sign language interpreter. She is currently the Director of Accessibility at the John F. Kennedy Center for Performing Arts in DC and oversees all of their accessibility compliance, policies, and accommodations for all performances, programs, events, and facilities associated with John F. Kennedy Center. She initiated and works on national and international projects such as the Leadership Exchange in Arts and Disability also known to or referred to as LEAD network of cultural arts administrators. And she currently, recently, not too long ago, got her JD degree and is currently licensed to practice law in the Commonwealth of Virginia. So you can see both their background and both of their bios on our website. You can read more information about both of them. If you wish to get more information, are very qualified in this particular area and we''re very pleased to have them join us today. So without further ado, I''m going to go ahead and I''m going to turn over the microphone to Kleo and she''ll start us out today. Go ahead Kleo.

Kleo King

Thank you Robin. Good afternoon everyone. I''m on the East Coast so it''s afternoon for me. As Robin said, we''re going to give you an overview of the ticketing regulations that came out in September 15th of 2010, under the Revised Department of Justice ADA Regulations. And I''m just going to give you a couple of sights for those who don''t have access to the slides Title II: State and Local Government. The regulations are found at 28 C.F.R Part 35 and for Title III: Places of Public Accommodation. The regulations are at 28 C.F.R. part 36. The regulations as I said were published September 15th, 2010. They became effective or enforceable on March 15th 2011, just about two months ago and the regulations also referenced the ADA Standards for Design which will become effective next March, March 15th 2012 and that affects the design for new construction and alteration and projects. So, what we''re doing today is we''re going to focus on the ticketing section of those regulations and the regulations cover basically eight areas which we''ll get into in more detail but I was going to just give you a summary of the eight areas. First, there is ticket sale, then there''s the identification of available accessible seating, ticket pricing, purchasing of multiple companion seats, release of accessible seats, transfer of tickets to third parties, acquiring tickets in the secondary market, and finally regulations outlining fraud prevention. So first, what types of tickets are covered? Basically, single event tickets, a series of events tickets whether it''s a subscription to the opera, season tickets for a football game, or season tickets for the baseball season. So that series of events tickets then there''s season tickets, subscription tickets and event packages. So, basically, anytime a venue sells tickets, whether it''s some type of a package, a single event or a series of events that are covered by the Americans with Disabilities Act and have to comply with the regulations. Ticket sales. Wheelchair companion seats, the accessible seat--seating are defined as a wheelchair seating area as well as the individual companion seats. A wheelchair seating area is basically a term of ours. It''s section that has specific dimensions, 36 inches wide and if you enter the seating area either from the front or the rear, it''s 48 inches in depth. And if you have to enter from the side, that is you coming to the seating area and have to make a turn in order to face the stage or the performance area or the field, is 60 inches wide or 60 inches deep by the 36 inches wide. And if there are two wheelchair seating areas adjacent to each other, the accessible seating is 33 inches for each wheelchair user. So that when we say accessible seating, the wheelchair space, that''s what that mean so is particular dimensions and then of course accessible seating also means that there''s companion seats adjacent to the wheelchair location. Also, for ticket sales, everyone has to have equal opportunity to purchase the tickets. So that means that if the tickets go on sale at the box office via telephone or online, the wheelchair, the accessible seating also has to be able to be purchased in those various venues and at the same hours of operation. So, again, if the box office is open from 8 to 4, the wheelchair or the accessible seating and locations also are on sale for those times as well as online at various ticket outlets and other, in the mall or other types of venues.

Betty Siegel

Kleo this is Betty. I want to jump in--

Kleo King

Hi Betty.

Betty Siegel

Hi! I want to jump in on the slide and emphasize again the fact that in section one what they do is they define what this section of regulation is talking about. And they are only talking about in this section of regulation; they''re only talking about the wheelchair accessible locations as well as the companion seats. The section is not intended to nor does it cover seating for patrons who are deaf, seating for patrons who are blind or have low vision. So the regulations have--e only addressing the wheelchair accessible locations and seating for visitors and patrons who have mobility disabilities.

Kleo King

Right. Exactly that''s a very good point to remember throughout the presentation for this section. Next slide

Betty Siegel

Oops, got to get there. There we go.

Kleo King

The second section is the identification of accessible seating. Again, this is the availability, the locations, the various features, the same--and what this section means in the regulation is that if a person does go online to purchase tickets and they can see the map, or there''s a brochure describing the various sections that has to be identical for the accessible seating as well as for the non-accessible seating so if there is a map where you can click on to see, you know, where you''re purchasing your seat, whether it''s on the isle or in the middle of a row, the same is true for the accessible seating. You have to be able to identify that in the same manner as you would with non-accessible seating.

Betty Siegel

Kleo, it''s Betty again. I get to jump in. I have the fun job of just being able to let you do all the work and then I get to jump in. One of the things that I think is really important for patrons and people at this place, who are taking advantage of this section of the regulation, is the concept of on request. Keep in mind, that if you call a venue and you are asking about purchasing tickets, you can ask that venue to identify the availability of all those seating locations. They don''t have to just do it, they have --but, if you request it, then they have to respond by giving you the location of all available accessible seating at the time that you call. So, it would basically be they would be giving the availability for what''s still on sale.

Kleo King

That''s correct. And that''s really an important new element this regulation introduces for people with disabilities ''cause you don''t have to just take the venues word for it any longer, "Oh yeah this is all we have." You can say to them, "Can you identify all of the available seating right now?" And then they''re going to have to give you that whole list.

Betty Siegel

Right. Based on where they''re located, the price range, various different features, that kind of thing, correct?

Kleo King

That''s correct. And I think another really key concept under this section is the website. Websites where people go to purchase tickets now have to be identical for people who are purchasing the accessible seats. If you are able to click on the two seats that you want and, you know, then the next step is entering credit card information. It has to be identical for people purchasing the accessible seating.

Betty Siegel

Now, Kleo its Betty again to jump in. When you say identical, do you mean exactly the same? I think with online ticketing there might be some cases where you actually have to do a couple of additional clicks but nothing that is onerous or burdensome in order to get to the wheelchair accessible locations.

Kleo King

Right. And also, I--they can also, if you click on say, wheelchair accessible seating location, it can tell you, you know, this seating is for someone who uses a wheelchair, you will remain in your wheelchair and in this seat. So there is the--when I said identical, what I meant was in the past there has been some online ticketing for various venues where you would fill out a form and then someone from the venue would call you and that''s how you would complete your purchase. Now, you are able to complete your purchase online. As a person who is purchasing a seat that''s not an accessible seat.

Betty Siegel

Yeah, that helps a lot because in the past, a lot of places did have you fill out an online form that even you''ve actually were submitting via e-mail and then after the fact, somebody would call you back and say, oh we got your form, now we''ll sell you the ticket. Now we hope that most people are going to get their ticketing online in real time so that a person with disability is purchasing their tickets in the same manner that everybody else is doing.

Kleo King

Right. And I think that''s a good phrase, real time. That''s really the key.

Betty Siegel

Yeah, One of the other things I think and I think you touched on this a little bit Kleo was this concept of what''s the feature of the accessible seating. For me, a feature as a venue, the feature of the accessible seating is that it''s a location where there probably is no chair or there''s a removable chair and has certain dimensions, either 36 inches like you mentioned by 48 or 60 or sometimes they can be 33 inches wide by 48 or 60 inches if you have two wheelchair locations adjacent to one another.

Kleo King

Correct. And the next slide kind of does go into the accessible features.

Betty Siegel

Oh should we jump there?

Kleo King

Sure.

Betty Siegel

Okay. Yeah, there they are.

Kleo King

So it''s the clear floor space that we had both talked about the 36 by the either 48 or 60 dimension depending on the approach to the space. It''s on, of course, it''s on an accessible route. The companion''s seat and the wheelchair location have shoulder-to-shoulder alignment. They''re at the same elevation and then the size, quality; comfort of amenities is equal to that of other seats in the area. So if other seats in the area have cup holders, the wheelchair locations and the companion locations have cup holders. If the companion location is a removable seat which is now permitted in the regulations, the quality of the removable seat has to be the same quality of the seating in that section. So if you have a padded seat with padded arms, your companion seat has to be similar. It can''t be, you know, a folding metal chair.

Betty Siegel

Not very much fun to watch an opera for three or four hours to be on a folding metal chair.

Kleo King

Right, exactly. [Laughter] So, I think that you''ll be seeing, you know, and again, based on price range the quality of the seat may go over down. You may have, say, in a ballpark, you may have seats that have the padded vinyl covering but then you also may have just the metal seats so the companion seat and the area would be the same as seats surrounding it. So a companion seat and a venue could differ depending on what section you''re seating in. And I think, next slide please?

Betty Siegel

Okay.

Kleo King

Ticket prices. Do I get to cover this one or you taking over?

Betty Siegel

This is Betty again. Highlights on this one are relatively simple but they get a little complex because you can never separate the ticket pricing from the venue itself. The regulations are pretty specific and they say that ticketing for a wheelchair user in wheelchair locations have got to be available at the same price level as everybody else has the opportunity to purchase. So, available at all price levels. And then it goes on to address the situations where you might be in an older venue, a venue that hasn''t engaged in any barrier removal, a venue that hasn''t done any renovations and it says if you cannot physically get your wheelchair users into all of your sections, then you should be looking at the wheelchair locations you do have and price them proportionally to the rest of the theater.

Kleo King

The one caveat on that is that you cannot price a wheelchair location any higher than the section in which it is located. So on this slide; I''m going to describe it to you for those that don''t have this visually. There is a very simple floor plan of a theater that''s divided into three sections; an orchestra section, which is usually the first floor level of the theater; a mezzanine that''s usually up one level, and; a balcony which would be your third level. In this theater we''re presuming that all of the wheelchair locations are located in the orchestra. This is not an unusual situation for older venues. Frequently, they don''t have even elevators that would take you up to the other levels so this pretend venue has all of its wheelchair locations, eight of them, in the orchestra, no wheelchair locations in the mezzanine or balcony, actually not even really any access there. And the seating in this theater though is priced by location so you have 100 dollar tickets in the orchestra, 50 dollar tickets in the mezzanine, and 25 dollar tickets in the balcony. So what''s the theater supposed to be doing in this situation? It''s supposed to look at the eight wheelchair locations which is 100 percent of all the wheelchair locations in the building that are all located in the orchestra level and then it''s supposed to price them proportionally because remember, the orchestra tickets are all 100 dollars. Everybody else who doesn''t need a wheelchair accessible location could choose to purchase a cheaper ticket in the balcony or the mezzanine at 25 dollars and 50 dollars respectively. But the wheelchair user really only has one choice of location so we want to try to give them the opportunity to also choose from all three price ranges. So we price proportionally in a theater with eight wheelchair locations. If 50 percent of the seats in the entire building are in the orchestra, you''re going to take 50 percent of those eight wheelchair locations which in this case would be four and you''re going to price them to 100 dollars. The mezzanine has 25 percent of the available seats in the building and so we''re going to take 25 percent of the wheelchair locations and price them at 50 so that gives me two wheelchair locations at 50. And then the balcony has 25 percent of all the seats and so I''m going to take the remaining two tickets in my orchestra section, price them proportionally to 25 dollars so I end up with wheelchair locations all in the orchestra where typically the seats are 100 dollars, four seats at 100, two seats at 50 and two seats at 25 dollars. Now let''s do, just for fun, the opposite scenario where you have all of your wheelchair locations in the balcony. What can you do there? Well, the balcony tickets are 25 dollars and since I cannot price my wheelchair locations any higher than the section in which they physically reside, I''m going to have to price all those wheelchair locations at 25 dollars. That''s about the most math that any theater person ever wants to have to do. So I hope that didn''t just totally confuse everybody and if it did, ask questions and we''ll address it at the end of the presentation but this is a really new concept for the--for you all that are out there purchasing these tickets. You''re going to want to be looking at the percentages and the distribution of the wheelchair locations as compared to all the rest of the seats in the venue and how--and that''s going to affect how those tickets get priced. I think for the user, and Kleo when--if you jump in on this, that might be useful. I think for the user it''s going to get a little confusing because you may end up seating, for example in this scenario, if you''re a wheelchair user, the person seating next to you may have paid 100 dollars for the ticket, you paid 50 dollars and the person over on the other side paid 25 and that happens because that venue is allowed to price those seats proportionally to the rest of the theater.

Betty Siegel

Right. Now that does happen and so, you know, it depends on where the seats like you say are located. If they''re all in one section, it''s a lot harder to, you know, price it according to the quality of the seat, but again, the person who is seating in the orchestra, which would be a better seat at a lower price.

Kleo King

Is there any, and way that Betty--you as a venue operator, I was going to ask a question, is there any progress on how they opt to sell the seats like do they have to sell the 25 before the 50 and then before the 100 or does it depend on what the patron is asking when they call up to purchase the ticket?

Betty Siegel

I think that the best practice in this area is going to be to take your guidance from the patron because the venue should be saying, you know, you want tickets for Wicked on the June 18th. We have tickets available at 100 dollars, 50 dollars, and 25 dollars. Now, they could stop right there and the patron would have to say, oh, I''m interested in the 25 dollar tickets. Hopefully, the venue because they are good customer service people will then go on to say, and all of those tickets for wheelchair users are in the orchestra level. So as long as we have 25 dollar tickets available, there''s probably no advantage to you buying the 100 dollar tickets at this point. But they may sell them out and this goes back to that other section where it gives you the right to ask what the availability of the tickets are because if they just say, we have a 100-dollar ticket, you have the right to say, can you tell me the availability of all the wheelchair locations and what the prices are?

Kleo King

Right. And that I would recommend that people who are purchasing the wheelchair locations especially in older venues that probably don''t have the wheelchair location spread out at every level, to ask specific questions, where are your 100 dollar tickets located, where are you 50 dollar tickets located, et cetera. And in that way, you''re very well informed and you would see where the 100-dollar tickets are, you know, orchestra center, the 50 are orchestra left and the 25 are orchestra right. And now you have a choice where would you like, you know, to actually purchase, which seat would you like and how much would you like to spend. So the more information that you get from the venue, I think that the purchase will be exactly what the individual wanted and needed.

Betty Siegel

Right, as a venue, we don''t want you being surprised when you show up. I would think that the best practice for venues is going to be to volunteer that information but if they don''t volunteer, you have the right to ask for it.

Kleo King

Right, exactly. So definitely be proactive and ask questions.

Betty Siegel

Absolutely. Shall we move on?

Kleo King

Yes purchasing of multiple tickets. The regulation now specifically state that a person who is purchasing wheelchair seating location, can purchase up to three companion seats contiguous and in the same row. If, and that mean this is a big if, capital IF, if they''re available at the time of sale. So if an individual wants to purchase a wheelchair location and three companion seats in a certain section, certain row and they''re available, they''re entitled to purchase the wheelchair location and the three companion seats contiguous to that location. If they''re not available in that section, perhaps they can move on to another section to find the configuration that they need. But if someone has already purchased the adjacent seats, the venue does not have to move those people that already purchased. So again, if those three companion seats are available at the time of sale. Now with that being said, that doesn''t mean that a wheelchair user who is purchasing the accessible seats can only purchase up to four seats. That''s just the contiguous requirement and in the same row. So if a wheelchair user needs to purchase six seats and one is a wheelchair location and the three companion seats that are adjacent, the other two seats can be located as close as possible. So it could be, you know the row and front perhaps. So that''s just an important number to remember that the three companion seats are adjacent, contiguous as the regulations say but a wheelchair user can purchase as many tickets as they want. Of course, if the venue like for some concerts, the number of tickets is restricted for everyone who is coming to purchase tickets. So if the restriction is two tickets or four tickets, the restriction would be the same for individuals purchasing accessible seating and Betty, from a venue point of view, if there are any hints you want to add or other points?

Betty Siegel

I think that this is going to be another one of those new, one of those sections of the new regulation that''s going to trip up a lot of people both the venues and the person--and the patrons who are purchasing tickets. The contiguousness, it''s interesting, I looked up the definition, contiguous just means touching. But the Department of Justice has clearly defined this as meaning in the same row. So when you''re looking at companion seats, I''m not going to look as a venue, I''m not going to look at the row behind you or the row in front of you, I''m going to look at just the row that you''re in because it says, and in the same row, to find those companion seats. If I can''t find you up to three companion seats that are contiguous and in the same row, then I''m going to start looking as close as possible. I hope the best practice of a theater is going to be to give you a lot of information at this point because the closest seats to those wheelchair locations, if we go back to the previous example where you''ve got all your wheelchair locations in the orchestra, in the 100 dollar seats, the closest available seats to those wheelchair locations are going to be 100 dollar tickets. So, you might end up buying the 25 dollar tickets, the two that are priced at 25 dollars and you''re looking for you other two companion seats and the closest available seats might be two rows forward at 100 dollars. I hope at that point the venue is going to be saying to you as a patron, I have tickets that are two rows forward at a 100 dollars but I also still have seats available in the balcony if you would prefer to purchase the 25 dollar balcony seats for you companions. And then leave it on you as the patron to say, what''s more important to you, is it more important to you that you''re companions to be close and that you pay a 100 dollars for their seats or that the companions be further away and you''re only paying 25 dollars for their seats? That''s a real important choice that the patron is going to have to be made--making as they go along. Kleo, I was at another conference recently and someone asked me a question and I had to explain to them that the three companion seats might also include purchasing an additional wheelchair location.

Kleo King

Correct.

Betty Siegel

And so the number of wheelchair locations that are available when I''m actually having to sell them to a wheelchair user and then use some of those locations as companion seats may be fewer than you''re used to in the past.

Kleo King

Right. Now they could and so if there are two wheelchair locations next to each other and a wheelchair user comes and asks to purchase the wheelchair locations and two companions, perhaps the venue can and fill the other wheelchair locations with folding chairs in order to accommodate that person. And again, that''s if it''s available at the time that individual called to make their purchase.

Betty Siegel

Now, I also think one of the unintended consequences of this particular section of the regulations is that in the past as a venue, I was going to hold tight to my wheelchair and my companion seat and I was going to always make sure that they sold together as a pair. Under these new regulations, you as a wheelchair user might end up finding out that when you go to buy your tickets there are no companion seats because somebody else before you purchased that companion seat as one of their three contiguous companion seats. And so you may find in the future that occasionally you''re going to be told that there is only a wheelchair location with no companion seats that''s contiguous to it and in the same row. And I think that''s an unintended consequence of this particular part of the regulations.

Kleo King

Right. Now I agree and so I guess the important point there is the quicker you purchase your tickets the quicker you''re going to get what you as individual need. So it''s basically first come first serve.

Betty Siegel

Absolutely. I think every one of these sections has this, a very key qualifier to it and in this case the key qualifier to your ability to purchase three companion seats is that it''s available at the time of sale. I think that''s really something that you have to keep in mind so buy early and buy often.

Kleo King

Definitely. [Laughs] The next section kind of goes the next step. Group sales; You''re coming as a large group whether it''s, you know, a social group or a large family is buying a chunk of tickets whatever, you know, the group sales tender more tickets. The group if there are one or more wheelchair users in the group, the group is seated near the accessible seating as close together if possible. If the group needs to be divided because there are not enough locations near the accessible seating to accommodate the group, then the groups is divided but the venue needs to be conscious that when they divide the group they''re not isolating the patron with the disability who has the accessible seats. So part of the group would stay with the person who needs the accessible seating and the other part of the group would go elsewhere. So it''s just, again, this is more a ticketing and seating issue for the venue. If someone is purchasing group sale then and they identify that they need accessible seating for individuals who are entitled and require the features of the accessible seating, the venue needs to deal with the group leader who''s purchasing the tickets so that the person with disability is not separated from their group completely. But, again, the group may need to be divided and just keep that in mind. Okay. Do you have anything to add as the venue, okay?

Betty Siegel

Nope. [ Laughter ]

Kleo King

Good. Highlights section 5: Hold and Release. So basically, a venue can release the accessible seats when all accessible seats--or all non-accessible seats are sold out. If the non-accessible seats are sold out in the area, then you can release the accessible seats in that area or in that price range. So, for example, if the orchestra level in a venue where there are wheelchair locations in the orchestra, the mezzanine and the balcony and the orchestra sells out, the venue can release the wheelchair location in the orchestra level. And while the wheelchair locations in the mezzanine and the balcony are still available because the mezzanine and the balcony have not yet sold out but as they sell out, they--a venue is allowed to release the wheelchair seating in those locations or in those price ranges. And again, that''s--a venue is allowed to release. They don''t have to. A venue can, and I do, I have dealt with a few venues that refuse to release. If it''s time of performance, they may have unsold wheelchair locations because they don''t believe their wheelchair or their accessible seating locations. Betty, I think I''m going to turn to you for the definition of sold out as a term of--for venues.

Betty Siegel

Absolutely. Here''s the interesting thing about this section to keep in mind. The Department of Justice declined, if you read the appendix to these regulations, appendix A, they actually talked about selling out. What does that mean? And the Department of Justice declined to define the terminology sold out. So the venue is left to decide what it means to be sold out and here''s the interesting thing about venues. Some venues define themselves as being sold out when absolutely every seat available is sold. In other words, there just aren''t any other seats to sell. Some venues will, will call themselves sold out when they have a certain number of what we call single seats. Meaning, the seats are not together, there is no pair of seats together. There''s one seat in the upper left, there''s one seat in the lower right section of the theater, there''s one seat in the balcony, there''s one seat in the boxes. Those single tickets are often times hard for venues to sell because most people want to come and sit with the person they came with and so the venue will say "well, we''re sold out" even though they actually do have these single seats still available for sale. And at that point, if that''s their definition of sold out, the Department of Justice said, you get to pick the definition of sold out. And so if I define sold out as being at the point where all the seats that are in pairs are sold out, then at that point I would be allowed to start to release my wheelchair locations. Another type of sold out that some venues use is that they will define sold out based on percentages. So at the point that the venue is 95 percent sold out, they''ll start calling that, they will start calling that performance a sellout. And by this regulation, at that point, the venue would be allowed to release the wheelchair locations. So I think the tricky thing here is that this regulation has made it so that every venue has to have the same policies in place to hold and release their tickets but every venue may have a different definition of sold out. So there is no guarantee that as a wheelchair user you''re going to be able to call me an hour before the show starts and presume that I will have tickets left because I may have released my wheelchair accessible locations because by my definition, I am sold out. So be careful about that one because venues can release the tickets when they are sold out and they get to use their definition of sold out. They can''t come up with ridiculous definitions. Oh, we''re sold out, when, the left hand section is sold out but not the right hand section or the third row is sold out but not the fifth row. It has to be a reasonable definition of sold out and probably one that''s fairly common for industry, for industry standard as sold out. But as soon as they''re sold out, they can release those wheelchair accessible locations. The only other trick Kleo, I think, with the sellouts is that a lot of times some venues will have seats that they call VIP seats and those don''t go on sale the same way the other seats go on sale. So if I have a lot of those kinds of tickets that basically I''m holding back for particular populations to purchase, I am still, according to the DOJ and the appendix, but not necessarily, this isn''t specified in the regulations and so, I should hold back an equitable number of wheelchair locations so that when I release those other holds, I release my VIP holds, I''m releasing the wheel--some wheelchair locations along with them. That, that''s a really confusing concept, I think, for people who are not in the box office business or in the venue business. So, again, I think, like Kleo said earlier, as a patron you''re going to have to be pretty savvy and when you call the venue to purchase your tickets, you need to take advantage of that opportunity to ask them to tell you what wheelchair accessible locations are available at the time that you''re calling.

Kleo King

And I think Betty as you were talking, I was thinking of the ways tickets are sold sometimes. Sometimes a particular credit card will be able to do advance purchase if you''re a cardholder of American Express or Visa or whatever the card is. So at that point, I think, the deal with, you know, if you''re a particular cardholder not only do they have seats but they also would have to include accessible seats within that promotion. And then when that promotion is over and they sold out at that point, would they be able to release the accessible seats for that promotion? Do you think?

Betty Siegel

I think they probably would be allowed to do that.

Kleo King

Okay, that''s what I just guessed.

Betty Siegel

Because usually that promotion is a price type. So you''re releasing the third condition under which I''m allowed to release is when I''m sold out in a price. So and I think at the point that these holds are no longer existent, then I would also expect to release the wheelchair location.

Kleo King

Okay, yup. That makes sense. The next slide is series of events tickets. And basically that, again, as we had said earlier is maybe season tickets or some type of package or subscription where you''re buying more than one performance or one game or one event. You''re buying, you know, however it''s sold whether it''s a season basis or, you know, some kind of a 10 performance package, something like that. If an individual by series of event tickets and at some point the venue sells out of their season tickets that are not accessible, they can release the accessible locations to a person without a disability. If the series, say a season ticket holder next year can automatically re-subscribe to their season that would be fine if it''s not the accessible location. If the accessible locations were released because of the sell out in the 2011 season then come the 2012 season, the person without the disability who bought the accessible seats doesn''t have an automatic ownership right. So, at that point, the venue would have to see if there is a person who wants to purchase the season tickets, if they''ve come forward, and again try to sell those--that season ticket to a person with a disability. And then, again, if a person with the disability doesn''t come forward for the 2012 season and all the other season tickets are sold out, they can release that season ticket package to a person without a disability but it''s not an automatic renewal. I think it''s the point. And the information the venue gives to the individual purchasing the accessible location would include that information that they don''t have ownership rights and it''s not going to automatically be theirs again for the next season.

Betty Siegel

Kleo, we have that situation with our subscribers and we are including little notices along with the person''s re-subscription, sort of to that effect stating these are wheelchair accessible locations, please let us know if you continue to need these locations because a member of your party is a person with a mobility disability or requires the features of that space.

Kleo King

Okay. The next slide is transfer of accessible seating to third parties and, again, it''s the same terms and conditions. So if an individual who has bought accessible seating because they needed the features and the accessible seating but they transfer their ticket, maybe they can''t go to the performance, something came up, and they give it to their neighbor who is not a person with a disability, doesn''t need the features of the accessible seating and they''re allowed to do that but the venue is not required to relocate the patron without the disability.

Betty Siegel

I think Kleo for patrons, one of the things as a venue that we hear sometimes is a wheelchair user someday will go and then they''ll look at the spaces that are wheelchair accessible and they''ll say, "I don''t see anybody in a wheelchair sitting there." And this part of the regulation is going to make that happen perhaps more often because if I''m a wheelchair user and I give my ticket to you Kleo and you go in using my accessible seating ticket, you''re going to be sitting in a wheelchair accessible location. And when you look over there you''re going to see Kleo sitting there then you''re going to say, she''s not a wheelchair user.

Kleo King

Right, exactly.

Betty Siegel

And I as a venue I''m going to say, "I know but she had the location and that''s where I had to seat her."

Kleo King

Right and, you know, and I think Department of Justice did this because individuals who do need the accessible seating may purchase something and if they can''t go, or they, you know, they sell it to their neighbor, they give it to their neighbor, they''re allowed to do that as a person without a disability who has a ticket to a performance and can attend, can give that ticket away. So again, I agree with Betty. I''ve gotten complaints where people are telling, you know, the wheelchair locations aren''t used by the people who need them. But, again, the person sitting there might or have legitimately come across the ticket and so you just can''t jump to a conclusion that, you know, they did not get the ticket legitimately and we will kind of touch upon that in a few more slides when we talk about fraud.

Betty Siegel

Absolutely.

Kleo King

And the next slide is about the secondary market. And this basically is any transaction after the initial purchase of the venue sell--puts there tickets on sale, people are buying tickets, but there''s also the secondary market where, you know, maybe it is a sold out performance or event and people go online and go to the secondary market and are able to purchase tickets. And--so if wheelchair a location is purchased on the secondary market, again, the venue has to honor the ticket. If a person who needs accessible seating purchases a ticket on the secondary market and it''s not an accessible location and they go to the event or the performance and they realize they bought seats that they cannot use, they can ask the venue to put them in a comparable location. The venue can do that if locate--if the location is available. Betty as the venue, you want to talk a little bit about the struggles you have when that occurs?

Betty Siegel

Absolutely. It''s because, again, this is an issue that as a patron, a purchaser of tickets you''re going to have to confront. So let''s say you do go on the e-Bay and you purchased two tickets and you get them in the mail and you notice that they are in a non-accessible location. You are going to want to present those tickets and then terminology in the regulation talks about, presentation of the ticket and you''re going to want to have to present that ticket to the venue as soon as you possibly can. Because the caveat on this section is that the venue only have to make the exchange into a wheelchair accessible location if the wheelchair accessible--if a comparable wheelchair accessible location is available at the time the ticket is presented. So you have to tie this back to that other section where we''re talking about hold and release policies and, remember, I can let my wheelchair accessible locations go if I''m sold out. . So if you walk in to the theater 5 minutes before the show is going to start and you say, "Here I am, I''m a wheelchair user and I''ve got an inaccessible location, I want you now to exchange these to a comparable location." I may say, "I''m sorry but I don''t have those because I''m sold out and I released all my wheelchair accessible locations." So the best thing you can do as a patron is to present your tickets and a presentation doesn''t mean a physical presentation. If you call the box office three weeks before the show starts and you say, "I''ve got these locations, they''re not wheelchair accessible. I''d like to exchange them." The box office is going to have to make that exchange three weeks ahead of time. The sooner you can get those tickets or notify or basically present those tickets to the venue, the more likely you''re going to get in to see the show because it''s more likely they''ll have the tickets to exchange them into. Don''t wait. Oh, please don''t wait ''til 5 minutes before show time. That can just be disastrous for all involved. So keep in might the important thing about this is your entitled to exchange--to have the venue honor that ticket that you purchased through e-Bay or any other secondary market but only if I''ve got the tickets available when you present them to me. Kleo, what about the concept of comparable? If I''ve purchased tickets on e-Bay for the 25 dollar seats in the balcony, would a comparable ticket be the 100 dollar seats in the orchestra.

Kleo King

I would think that a comparable would not mean that. But if they are available, perhaps the venue could offer that and see if the person wanted to upgrade, you know. But then I''ve also dealt with venues who say if it''s time of performance and the seats going to go empty, you know, I put the wheelchair user there because, you know, why, you know, turn him or her away when I have this seat sitting there empty. But, again, I think that''s going to be a venue''s choice because the balcony and the orchestra are I would say are not comparable. And now what happens if the reverse, I was going to ask you Betty, if the person has the 100 dollar ticket and comes in and you say, "Well I''m sorry, the only wheelchair location I have available is the balcony" and although they''re 25 dollar seats, it''s not up to the venue to reimburse that person 75 dollars.

Betty Siegel

No, it definitely wouldn''t be because we weren''t apart of the exchange to get those tickets.

Kleo King

Right. So the transaction and the issue is really with the secondary market, not with the venue and, you know, the venue is now trying to accommodate the individual and try to find them either a comparable seat if it''s available so there is no issue. You bought a 100 dollar ticket, you''re in the 100 dollar seats but then, you know, if the venue says, all I have left is the 50-dollar seats, you know, the patron has to decide do they want to sit there? Do they want to, you know, not go to the performance but then what''s the likelihood that they''re going to get any of their money back from a secondary market?

Betty Siegel

Probably a zero.

Kleo King

Right.

Betty Siegel

Most venues, I think, has a best practice. Most venues, if a wheelchair user comes in with a non-accessible location, most venues are going to make every effort to accommodate that patron but it''s going to be based on what they''ve got available at the time the patron presents the ticket.

Kleo King

Exactly.

Betty Siegel

That''s really key for you as a wheelchair users and patrons using those tickets. Present your ticket as soon as you possibly can. We''re on to the last slide and I think this is timing out just perfectly so we can do this final point Kleo and then move in to Q&A.

Kleo King

Okay, good. Yeah, the final point is preventing a fraud and that is always the hot topic whenever I''ve done a presentation like this. Fraud happens. There are people out there that aren''t nice people who call up and pretend that they have a disability because maybe the only seats available in that section at the moment are the accessible seating. So a venue, how do they prevent fraud? And basically, of course, a venue cannot ask for a proof of disability. They can ask for a verbal statement that if a person is buying an accessible seat for a single event, they can ask the individual if they, you know, need the accessible features of that location. If it is a subscription or series of events tickets, they can ask that the individual purchasing the tickets provide a written attestation that says basically that they or a member of their party, have a mobility, disability or a disability that requires the features of the accessible location. And, again, I mean it''s the honor system. You know, a person who has the disability and needs those features is going to say, yes, you know, I''m a wheelchair user. Yes, I need the accessible locations or the person who''s coming with me needs the accessible location. If a venue believes that a person is fraudulently purchasing the accessible locations, they can investigate. That maybe, you know, a person without--who doesn''t need the features, shows up game after game after game after game and, you know, they may at that point want to investigate that person--acquire the tickets fraudulently or did they get them legitimately? So, I think, the burden to prevent fraud is really on the venues. Betty, I think from a venue standpoint, I''d like to hear what you have to say.

Betty Siegel

I think the burden is definitely on the venue to make every effort to prevent fraud but, again, the unintended consequences of this particular section in the new regulations really limits the venues options for doing that. You have to tie it back to those other sections. I have to let in somebody. I have to honor the ticket. If the patron acquired it from a person who''s a wheelchair user under the section about the transferring, I have to put my wheelchair accessible locations, at least some of them if not all of them, online for purchase and online there is even fewer protection. I do have to make sort of a side note here which is to say that you may find when you''re purchasing wheelchair accessible locations online that you''ll have to click a box that is an attestation that you actually need it. Though I might say, before you actually are allowed to purchase the tickets online, it may ask you the question. This is just to confirm that you or a member of your party is a person with mobility disability, et cetera. And that''s the equivalent to the verbal attestation that I will be entitled to ask you over the phone as the venue. But if you think or suspect that there''s fraud going on in the purchase of tickets, you''re going to have to notify the venue. The venue is going to have to make a determination as to whether they have good cause and if they do, they''re going to do their best to investigate the abuse of those tickets. But other than that, there isn''t much the venue is going to be able to do. So this is a little bit of a tricky sticky section here.

Kleo King

Right. Now, there is really no good solution to fraud, unfortunately.

Betty Siegel

No. You know, I don''t see a lot of fraud happening for Placido Domingo''s singing in the, you know, in the [inaudible]. But I think this is a much bigger issue when you''re getting into the sports arena, the big concert arena, et cetera. For your general theater, I think, there''s not a lot of abuse going on but in the larger venues there may be and your best bet is to inform the theater, the venue, the stadium so they can look into the fraud if they feel they have good cause to do so.

Kleo King

Right.

Betty Siegel

So we''ve covered all of our sections now so if anyone has questions.

Robin Jones

At this time, we''ll have Stephanie provide instructions to our participants by phone and they can cue in to ask questions and anyone who is using the online system either the webinar platform and/or the streaming audio can please go ahead and submit your questions using those systems and we''ll relay them to the presenters. So Stephanie, you want to give the instructions?

Operator

Ladies and gentlemen if you have a question at this time, please press the star then one key on your touch tone telephone. If you''re question has been answered or you wish to remove yourself from the queue, please press the pound key.

Robin Jones

While we''re waiting for some folks to cue in some questions, I do have one that was submitted to me electronically by e-mail and. And it said if there was any concern or do you think that there are any differences related to the use of paperless tickets now? So much, you know, on the internet such that nature with fraud or other problems with people, you know, purchasing and getting the right tickets and the right seats and things that ensure verification this person is saying that had struggle with verification that they actually got the seats that they think they bought. When they go to the paperless tickets they type things where they don''t necessarily have a piece of paper or something the same as you might and traditionally had a ticket any thoughts on that from either of you?

Betty Siegel

This is Betty. I''ll jump in on that one. I think that the proliferation of variety of new ways to demonstrate that you purchase tickets or the ability to sort of flash your iPhone at me, the ability to print at home tickets, all of these are leading to, people are clever. They''re going to figure out a way to try to beat the system and so they are leading to new ways in which people are trying to scam the venues. If you print two sets of your tickets at home and you take one copy that you printed and hands it off to another person or you Xerox that copy and hand it off to another person, we could end up as the venue, having two, four, six people all for one seat. And that is a concern of all the venues and I think everybody right now is doing their best to deal with that form of fraud. I think it''s not going to be any worse for the accessible seating. I think that the issue right now is that venues just have to get smarter than the people who are trying to outsmart them.

Robin Jones

Right. Thank you. Stephanie, are there questions from the telephone audience?

Operator

please press the star then one key. Our next question comes from Debbie Jackson, your line is open.

Caller

Hi Betty. This is Debbie Jackson, I''m at Hawaii. I met you at the National ADA Symposium last week. And I have a question for you. If a venue, like the example that you gave with the orchestra seating and the mezzanine and the balcony, say that they can''t get all of the accessible seating in the orchestra section, what does the venue do then?

Betty Siegel

Kleo might be able to help us with this question because this has to do with barrier removal.

Kleo King

And, right. An existing facility under the 1991 standards has to remove barriers to the extent that it was readily achievable and was an undue burden so that if the venue cannot get their full number of accessible seating based on the size of the facility, they have to get as many as they can in order to remove the barrier. And this is--barrier removal is assuming that that''s not new construction since ADA went into effect and if there hasn''t been alterations that would trigger accessibility requirement. It''s strictly you have to go in and you have to remove barriers. So that say, in Betty''s example, where she needed eight wheelchair locations, if there was only room in the back row where she could get the accessible route to the seats and then you had the requirements for the seating and the companion seat and the venue was only able to achieve seven and they needed eight, but, you know, in barrier removal they couldn''t get that eight seats anywhere else and the theater was out, you know, doing a massive renovation, they wouldn''t have to do it. But, again, you have to weigh what''s readily achievable, what can be done, the configuration of the theater. You can''t go to the next row in front because now the theater--the floor slope and you can''t have an accessible location that, that slopes. It has to be level so it''s going to differ from venue to venue and it''s basically, you know, what is readily achievable when it comes to barrier removal.

Betty Siegel

I don''t want people to think that this is an excuse. Barrier removal is not sort of a blanket exception for anybody. It means you have to try to get to the full number of seats you''re required to get to under these appropriate standards, the 1991 or the 2010 Accessible Design Standards. So I would push on any venue that doesn''t have the minimum required number to see if you can''t--they can''t find a way to remove those barriers. Sometimes they won''t be able to do it but sometimes they can and they''ve just been lazy. So if you don''t, if they don''t have them and they can''t get them, that''s one thing. If they haven''t bothered to try, that''s another.

Kleo King

Right. And barrier removal is ongoing. So if, you know, it''s been over 20 years, in 20 years a lot can be done. So if in the 5 five years when they--after the ADA became effective, if they provided three wheelchair locations, that didn''t stop their obligation to continue removing barriers to the point where there, you know, fully accessible. And again, if they''ve undergone any renovation, the renovation that they''ve done needs to comply with the ADA and the accessibility guidelines.

Robin Jones

Wait, well that leads me into a question that''s been submitted online here saying, the new regulations still require a line of sight over standing spectators so this is another architectural question that I don''t know Kleo if you want to step in and handle that particular inquiry.

Kleo King

Line of sight and dispersion is addressed in the design guidelines and so the short answer is yes, that wheelchair spaces have to be dispersed. They have to have a choice of seating locations and viewing angles that are equivalent to seats that are not the accessible seats and if the venue has performances or games that where spectators are expected to stand, then the low accessible locations have to have viewing angles over the standing spectators.

Betty Siegel

And I think this is an issue in particular for sports stadiums and, again, large concert venues. I think the only time at the Kennedy Center that we really expect people to stand is during the Hallelujah chorus which we do once a year at Christmas time. So, generally, for the opera there''s not an expectation that we''re going to have standing spectator so this line of sight issue can vary depending on what the venue is like.

Robin Jones

Great. Thank you. Any additional questions please Stephanie from the queue.

Operator

Again ladies and gentlemen, if you have a question at this time, please press the star then one key.

Robin Jones

Okay. I''m going to enter another question here that I''ve received. We get a lot of questions from people, you know, some were concerned that the reduction--that the architectural standards have done and the number of seats that are required in large venues is in direct conflict with the ability now for an individual to buy, you know, three contiguous--you know, additional seats and so with fewer wheelchair seating, seats are casually required under the standards. And such do proceed or do you think or you know or could you give any background on potential, how this might impact, you know, the reduction of the number in contrast to the number of seats I can now purchase and essentially taking up wheelchair accessible seats with people who are not--who do not need the wheelchair accessible seats because of the way the regulation is written?

Betty Siegel

This is Betty. I''m going to--the regulations, that particular change in the standards, the new ADA standards really hits venues at 5,000 seats and above. I''ve done the numbers. I''ve run numbers through different sized venues and the reduction and the number of wheelchair accessible locations for venues under 5,000 seats is really not significant. There is a reduction though when you get up to those higher numbers and Kleo you''ve worked more with stadiums and the really, really large venues, do you see a significant change happening there?

Kleo King

Well, with the--they have basically reduced by half in the larger venues, the ones that are over the 5,000.

Betty Siegel

Right.

Kleo King

But there were a lot of new studies that Department of Justice looked at and a lot of the locations, you know, the whole, the full 1 percent was not being utilized. Now with the reduction and the way each venue is configured, I think there could be an impact especially in the example that we had used earlier where the three companions are now taking over wheelchair locations by infilling with the removable seats. So I think that larger venues really need to start looking at that to see how the new regulation and the reduced numbers and with the advent of the three companions is going to impact the accessible seating locations to see, you know, how many people are in fact turned away if any because we don''t have the numbers. We have the numbers based on purely one wheelchair user, one companion and the--and the larger venues the seats were not being fully used. But now with this new, with the addition of, addition of two extra companions, how is that going to impact it? And I think, you know, three years down the road, I would be really interested in seeing the numbers and, you know, if it does impact it significantly, maybe advocacy groups go back to Department of Justice and say, and try to figure out what, what will be equitable at that point. There''s a chance that there will be a huge impact in smaller venues. We have to remember that the designers, our architects, built all these venues with the idea of one companion seat, one wheelchair, one companion seat, one wheelchair and when there'' not always the flexibility to find the additional two companion seats without having to use up a wheelchair location. So I do think that, I personally have some concerns about the availability of wheelchair accessibility locations. On the other hand, the reason why they allowed for those three additional companion seats is because there was so much pressure and outcry from the disability community which I think was perfectly valid saying, we don''t want to--when I come I want to seat with my friends. I want to, if I''m a grandparent, I want to seat with my two grandchildren. I don''t want to have to sit separate from them. The combination, I think, of the reduction in the number of wheelchair locations being required under the design standards and then the increase in the number of companion seats, I think, is not the best combination.

Robin Jones

Yeah. They think because they were done separately, once done by the accessibility guidelines developed by the ADA and the second was hard to change made by Department of Justice. I think that, you know, some of that disconnect, you know, does occur in that. Do we have any additional questions through the telephone line, Stephanie?

Operator

Yes, our next question comes from Rick Edwards, your line is open.

Caller

Hi. My question is--my name is Daniel Pittman. I''m legally blind and I was wondering if there was mention about accessibility for visually impaired and low vision? How would that be accommodated for somebody with my limited vision being able to be able to see any kind of event, how would that accommodation be done?

Betty Siegel

This is Betty. I''ll, I''ll start and then let Kleo take over ''cause I want to do the easy part of that question. Just so you know Dan. The, these regulations in the first section specifically say that the only things these new regulations are addressing are the wheelchair accessible locations. They are not addressing the issues of patrons who are deaf and hard of hearing or patrons who are blind and have low vision. That does not mean that the venue is relieved of any obligation to you. It just means that under these regulatory changes, these new regulations, there''s--you''re not covered here. But Kleo, I think they still have an obligation under just the general modification of policies, practices and procedures to make an effort to accommodate patrons who are blind or have low vision.

Kleo King

Right. Now, I agree. It''s, you know, again, you''re going to try a reasonable accommodation, what you--what does the individual need, what does the venue have to offer. And I think more and more venues are looking at patrons and fans that have disabilities that affect vision and, you know, do have accommodation. So, definitely, call the venue box office, tell them what you need and, you know, try to work through it to get the seat location that you need.

Robin Jones

I think that the, this is Robin. A little of disconnect between some of the things the Department of Justice is putting out and the guidelines to venues and it really is all up to the venues to figure out how those accommodations are made because the Department of Justice has not necessarily supported even a requirement for low vision seating or for reduction of any, you know, ticket prices or first opportunity for the first row at a, you know, if you''re at an orchestra and that''s the closest seating and that''s a 200 dollar ticket, there is nothing in the ADA regulations at this time that would require that they sell a cheaper ticket to someone because they needed that closer location. And that''s where there continues, I think, to be some advocacy needs within the various communities to look at potential future changes in the regulations for more language and more guidance to the venues on this particular issue ''cause it really is left up to venue by venue as to how they operationalize it and there isn''t much in the regulatory language that really requires them to do anything especially when it comes to pricing and things like that. Additional questions Stephanie?

Operator

I''m sorry. No further questions at this time.

Robin Jones

Okay. I have one that was submitted by electronically related to the accessibility of the websites. Really, you didn''t talk about that from a protection, you know, the accessibility to different things. The accessibility to be able to get in there and find the seat I need accessibly but then there''s the accessibility of that with somebody who may be using assistive technology and such to be able to navigate on the website. Betty or Kleo, can you say or [inaudible] at all in regards to any leverage that the new regulation give to ensuring the accessibility of the web-based ticketing process?

Kleo King

Definitely, the regulations they are pretty clear even though they never use the term online or web in the regulatory language. Again, if you go to the appendix and you look at the Department of Justice''s discussion with itself about why it''s making certain choices, it says it thinks that web accessibility is, has always been covered by the ADA but that''s not the regulatory language so that leaves us kind of hanging here, wondering exactly what''s going on.

Betty Siegel

I think that a lot of people, including me, in the disability community feel that web accessibility is covered and that we need to ensure that the actual ticket buying process is accessible to screen readers and people using the alternative means of access to the information. Kleo, do you have anything that might clarify that situation?

Kleo King

I''m, I agree with what you say Betty and I think there have been some cases based on websites of different kinds of accommodations that and settlements that Department of Justice has entered into. But I do believe that, you know, they do have to be accessible and that venues and entities that do transact business through a website or online or however you want to say it, do have to take into account, screen readers and other kinds of accommodations. So why wouldn''t, you know, they need to take into account. So if, you know, there''s a photo on the website, then it should quoted in the background so the screen reader can say, you know, it''s a photo of such and such or whatever. So I think that venues need to look at their websites and their resources and make sure that they accommodate everyone. Now, just to play the devil''s advocate a little bit, remember, there''s nothing in the regulations ''cause in 1991 we weren''t thinking about internet access and web accessibility. There''s nothing in the regulations that talk specifically or says so cleanly in black and white, yes your website must be accessible. The Department of Justice just had out into DPR notice of proposed rule-making that actually ask people to comment on that specific issue with the thought in mind that in the near future, the Department of Justice would be issuing new regulations that would specifically address the issue of web accessibility.

Betty Siegel

Right, and spell out on how to do it and have, you know, better guidelines but, I think, venues just need to keep that in mind and be conscious that it is, you know, there is technology out there now and look at it because someone may complain. And if they complain to a Court or Department of Justice, you know, who''s going to prevail? I just think it''s just wise to start taking into account now technology''s come a long way in the last 22 years.

Robin Jones

And I think, this is Robin, just have to say this. It should be approached so much like you''re building a building or renovating a building, it''s not something you can do overnight. Because anyone who''s worked with websites knows that there''s a structure to the website and there''s a way that things that are added and done and you just can''t go in and, you know, magically tweak it to suddenly become accessible. It is like building a structure and it does take planning and it does take an infrastructure, you know. I''m there as an architecture [background noise] to websites that definitely needs to be addressed. So in that regard--sorry about that, I''ve got a line ringing here. So in that regard it''s supposed to be addressed so.

Betty Siegel

Right, yeah. I agree Robin and so if you do have a web designer or you''re looking at upgrading your site, you know, ask them about, you know, are there technologies out there that would just serve my constituents better, you know. We''re all in customer service so the more customers you serve the better.

Robin Jones

Okay, well thank you very much. And I''m just going to check one more time to see if there are any additional questions. Does anyone is submitting through the telephone please?

Operator

Again ladies and gentlemen on the phone line if you have a question at this time, please press the star then one key.

Robin Jones

Okay as we proceed and wait and see--

Operator

I''m sorry. No further questions at this time.

Robin Jones

Okay thank you. As we just finalize here, you''ll see some resources have been provided by our speakers, US Department of Justice, Civil Rights Division Disability Rights Section. Their website, www.ada.gov and you''ll see their phone number 800-514-0301 voice. I just want--also I to give you the TDD number for the Department of Justice Civil Rights Section is 800-514-0383 for TDD direct access. I also encourage you to contact the ADA National Network also known as the DBTAC, Disability and Business Technical Assistance Center. We are geographically located across the country and are funded in by the federal government and available to respond to your questions or direct you to the areas that you may be able to get some answers to your questions. So, again, we''ve already went through the questions so this particular slide is a new point our presenters. This is how you go ahead and contact them. They have provided you with their contact information. Very brave souls they are to do that. Feel free to e-mail them or telephone or e-mail as you see provided to you here and they''ll respond to your questions as they''re able to if you have any particular issues that you might want to bring forward to them. As I said, this session was recorded today and we will be making it available on our website within approximately 10 days at www.ada-audio.org. We invite you to join us at next month''s ADA Audio Conference Session which is titled Reasonable Accommodation and it features Dr. Ellen Fabian and Dr. Kim MacDonald who both are associated with the Mid Atlantic ADA Center and the University of Maryland and they will be discussing the issues of reasonable accommodation. So we invite you at same time, same place. You can get more information and register at the website, again, www.ada-audio.org. At this time, I would like to thank our presenters both Kleo and Betty for their time and their expertise. Today, these are very complex issues that everyone is really, you know, struggling to get through, and I don''t want to say struggle as a negative, I think are working to get through. This did go into effect in March of this past year ago--a month or so ago so they are in effect right now. So these are issues that are impacting you as you''re getting your summer together and looking all the concerts and all of the events and venues and buying up your championship tickets for, you know, whatever team you might be cheering on for right now in the playoffs or whatever else there might be. This is all current and in effect right now and one of the things that we''re finding out with the new ticketing regulations that many venues have started to have kind of ha moments about other areas of the ADA that they might not have been in compliance with that the new regulations have really highlighted. Again, the seating issues, they''ve never really addressed fully there, you know, seating and where it''s positioned and such in their venues and things. So might still continue to find even though we say 20 later that a lot of these things should have been resolved. I think that every time we do tweaks or changes to the ADA regulations, we do find that there''s a cadre of people out there who are not fully up on what the ADA required even before these changes so this is an area that many of you still may find frustrations with but, hopefully, you''ll find also at the same time some success in getting better seating and some better information about the seats that you''re seeking to sit in. So, thank you very much everyone for joining us today. You will receive an e-mail shortly after the session with your registration, with the evaluation information, online evaluation. We do encourage you to complete it for us. We do value your feedback. So thank you very much and have a good rest of your day.

Operator

Ladies and gentlemen that concludes today''s conference. You may disconnect and have a wonderful day.