For the second time this month, the world’s dominant ticket seller is turning to the media to clear up what it believes are misconceptions about its business model.

With its proposed merger with Live Nation in the final stages before a regulatory ruling, Ticketmaster is going on the offensive to polish its image deflect criticism that the company is to blame for sold-out events.

In a commentary piece on MPR NewsQ, Minnesota Public Radio’s Web site, Ticketmaster’s senior vice president and assistant general counsel Joe Freeman tried to make it clear that artists are more to blame when concerts sell out than Ticketmaster.

“When popular events are placed for sale on our system, consumer demand overwhelms ticket supply and our inventory of tickets can be depleted within minutes (our systems can process and sell thousands of ticket orders within that time),” Freeman wrote, stressing that Ticketmaster doesn’t own the tickets its sells; doesn’t “hold back” or “divert” tickets to other Web sites; nor does it give preferential treatment to certain brokers. “This challenge is exacerbated when our clients hold back significant amounts of tickets that are not initially (or ever) made available for us to distribute, or when they dictate that the vast majority of tickets be made available via fan club or promotional presales.”

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He continued, “Again, we do not decide how many tickets will be made available for any event or for a particular presale or general sale; event providers are specifically and solely responsible for deciding the number of tickets provided to Ticketmaster to sell.”

During the summer, Ticketmaster Entertainment CEO Irving Azoff was accused of orchestrating a scheme, code named “Project Showtime,” where he reportedly funneled premium tickets to certain brokers that he tried to acquire on behalf of Ticketmaster. The dealings occurred a year before Azoff, one of the nation’s most influential music artist managers, became CEO.

Freeman, who oversees Ticketmaster’s North American government relations program, was reacting to proposed legislation in Minnesota that strengthen the state’s ticketing laws, but which could also tie Ticketmaster’s hands by requiring it disclose all that are being made available for a particular event.

“When you further consider that an individual ticket request can be as large as six or eight tickets per order — a limit determined by the event provider and not by Ticketmaster — it becomes clear why we are unable to satisfy more than a fraction of those fans interested in buying tickets for the most popular events. And that’s true even as we make tickets available for sale in strict accordance with our clients’ instructions,” Freeman wrote.

Last week, Freeman wrote a similar commentary in a Canadian newspaper to try to state its case as the Saskatchewan government looks to strengthen its ticketing rules. While Ticketmaster often responds to criticism, the commentaries mark a more aggressive tone in the company’s efforts to spread its message.

“Ticketmaster can be an easy political target, and we make our share of mistakes. But thoughtful and effective public policy cannot be predicated on misunderstandings or misinformation,” he added.