Patty Hayes owned four Personal Seat Licenses (PSLs) at the Cleveland Browns Stadium. Hayes’s PSLs reserved four seats on the 50-yard line, at the railing, on the north side of the stadium. As the owner of the of the PSLs, Hayes was obligated each year to purchase season tickets for the seats, which she could then use or sell. Failure to purchase season tickets would result in the PSLs reverting back to the Cleveland Browns and the seats being available to those on a waiting list.