eChanging Barcode, LLC v. MLB Advanced Media L.P.
- Paul Engelmayer
- 1:24-cv-02930
- U.S. District Court · Southern District of New York
- 20
In eChanging Barcode v. MLB Advanced Media, Judge Engelmayer denied dismissal, finding the ticketing patent’s eligibility plausible at both required steps.
eChanging Barcode’s patent-infringement claim against MLB Advanced Media remains pending after the court denied the motion to dismiss. MLB Advanced Media may challenge patent eligibility at a later stage, as the court expressly preserved that ability.
What happened
eChanging Barcode, LLC sued MLB Advanced Media L.P., alleging that MLB’s “Protect the Barcode” system infringed its patent for rotating digital ticket barcodes. The patent describes changing electronic access credentials, linking them to devices and users, and applying time- and location-based restrictions to reduce counterfeiting and unauthorized resale.
MLB Advanced Media asked the court to dismiss the infringement claim, arguing that the patent covered an abstract idea and therefore was not eligible for patent protection under federal patent law. eChanging argued that the patent claimed a specific technical method that improved on static ticketing systems by dynamically generating, transmitting, displaying, and authenticating rotating barcodes.
Judge Paul A. Engelmayer denied the motion to dismiss, without prejudice to MLB Advanced Media challenging patent eligibility later in the case. The judge held that, based on the complaint, the patent was plausibly directed to a specific technological improvement and plausibly contained an inventive concept, but the ruling did not finally decide that the patent is valid.
The detailed version
- eChanging Barcode, LLC v. MLB Advanced Media L.P. · No. 1:24-cv-02930
- Paul Engelmayer
- May 30, 2025
Background
eChanging Barcode, LLC alleged that MLB Advanced Media L.P.’s “Protect the Barcode” technology infringed U.S. Patent No. 9,047,715. The patent concerns credential management for event tickets and describes electronic access credentials that rotate over time. The complaint alleged that the patent improves on static tickets by using rotating visual symbols, linking portable devices to users and access restrictions, transmitting credential information wirelessly, and applying time- and location-based limits.
The complaint alleged that MLB Advanced Media’s ticketing system uses its MLB Ballpark App and rotating digital barcodes. According to the complaint, the system changes the displayed barcode, uses time- and location-based restrictions, and is designed to prevent screenshots, duplication, counterfeiting, and fraud. eChanging sought damages and an injunction for alleged patent infringement.
Motion and legal framework
MLB Advanced Media moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that the patent claims ineligible subject matter under 35 U.S.C. § 101. A Rule 12(b)(6) motion tests whether the complaint alleges enough facts to state a legally plausible claim. At this stage, the court generally accepts well-pleaded allegations as true and draws reasonable inferences for the plaintiff.
The court applied the two-step framework from Alice Corp. v. CLS Bank International. First, it asked whether the patent claims were directed to an abstract idea, such as organizing human activity or controlling access. Second, it asked whether the claims included an “inventive concept”—additional features that transformed an abstract idea into a patent-eligible invention.
Step one: abstract idea
MLB Advanced Media characterized the patent as merely claiming the abstract idea of controlling access with changing credentials. The court rejected that characterization as too general because it did not account for how the claimed system operated. The claims described sequential technical steps involving a server, device identifiers, users, access restrictions, visual symbols, wireless transmissions, and defined time intervals.
Based on the complaint, the court found that the patent was plausibly directed to a specific technological improvement rather than merely to the everyday concept of credentialing visitors or controlling access. The court therefore concluded that dismissal was not warranted at the first step.
Step two: inventive concept
The court separately held that dismissal was unwarranted even if the patent claims were directed to an abstract idea. It found plausible allegations that the claimed rotating-barcode system improved traditional static ticketing methods by dynamically generating and managing credentials, associating devices with users and restrictions, managing visual symbols at a credential-administration server, and displaying rotating credentials according to server instructions.
The court distinguished cases involving the automation of conventional credentialing processes. In the court’s view, the patent’s alleged use of rotating barcodes to reduce unauthorized duplication and counterfeiting described more than the use of a generic computer to perform an existing human process. At the pleading stage, those allegations plausibly described an inventive concept.
Disposition
The court denied MLB Advanced Media’s motion to dismiss the amended complaint, without prejudice to MLB Advanced Media’s ability to challenge patent eligibility at later stages of the litigation. The court did not finally determine that the patent is eligible or valid; it decided only that the allegations were sufficient to prevent dismissal at the pleading stage. Judge Paul A. Engelmayer directed the clerk to terminate the motion at Docket 57 and stated that a separate order would schedule an initial telephone conference.
Read the full 20-page opinion on CourtListener, the free public archive maintained by the Free Law Project.