DCT
1:25-cv-08983
Echanging Barcode LLC v. Ticketmaster LLC
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: eChanging Barcode, LLC (Delaware)
- Defendant: Ticketmaster, LLC (Virginia) and Live Nation Entertainment, Inc. (Delaware)
- Plaintiff’s Counsel: Hecht Partners LLP; The Law Offices of Gerard F. Dunne, P.C.
- Case Identification: 1:25-cv-08983, S.D.N.Y., 11/13/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Southern District of New York because Defendants have committed acts of patent infringement and maintain a regular and established place of business in the District.
- Core Dispute: Plaintiff alleges that Defendants’ SafeTix digital ticketing technology infringes a patent related to dynamically changing, time-limited visual credentials, such as barcodes, to prevent fraud.
- Technical Context: The dispute is situated in the digital event ticketing industry, where preventing ticket fraud from unauthorized duplication, such as via screenshots of static QR codes, is a significant commercial and technical challenge.
- Key Procedural History: The complaint notes that in a separate case, eChanging Barcode, LLC v. MLB Advanced Media L.P., a court in the same district previously held that the claims of the patent-in-suit were not directed to a patent-ineligible abstract idea under the Alice framework, a finding that may influence early motion practice in this case. The complaint also alleges that Plaintiff’s inventor disclosed the patented technology to a Live Nation executive in 2011, years before Defendants launched the accused product.
Case Timeline
| Date | Event |
|---|---|
| 2011-08-02 | ’715 Patent Priority Date |
| 2011-10-XX | Inventor Alan Amron allegedly emails Live Nation executive regarding the technology |
| 2011-11-14 | Live Nation executive allegedly responds to Alan Amron |
| 2015-06-02 | U.S. Patent No. 9,047,715 Issues |
| 2019-XX-XX | Defendants launch SafeTix technology |
| 2025-11-13 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,047,715 - "System and method for credential management and administration"
- Patent Identification: U.S. Patent No. 9,047,715, "System and method for credential management and administration," issued June 2, 2015 (the “’715 Patent”).
The Invention Explained
- Problem Addressed: The patent’s background section describes the problem of unauthorized duplication and counterfeiting of credentials (such as event tickets, badges, or passes) which becomes acute when static identifiers are used, as they can be easily copied with modern scanners and printers (’715 Patent, col. 2:23-44). This vulnerability creates financial loss and security risks (’715 Patent, col. 2:45-48).
- The Patented Solution: The invention proposes a centralized "credential administration server" that manages and distributes secure electronic credentials to portable devices like smartphones (’715 Patent, Abstract; Fig. 1). The core of the solution is that the server provides each device with a unique, machine-readable visual symbol (e.g., a barcode) that is valid only for a specific, limited time interval. After the interval expires, the server provides a new, different visual symbol for the next interval, rendering any copy of the old symbol invalid (’715 Patent, col. 3:12-34).
- Technical Importance: This approach of periodically updating credentials from a central server was designed to defeat counterfeiting methods that rely on copying a static image, such as taking a screenshot of a mobile ticket (Compl. ¶18).
Key Claims at a Glance
- The complaint asserts infringement of claims 1, 19, and 41, which are all independent method claims (Compl. ¶¶19, 43-46). Representative Claim 19 includes the following essential elements:
- Associating a first portable electronic device, having a unique identifier, with a first user at a credential administration server.
- Obtaining first visual symbol information for the device to display a first machine-discernable image during a first specified time interval (between 30 to 6000 seconds).
- Providing instructions for and wirelessly transmitting the first visual symbol information to the device.
- Obtaining second visual symbol information for the device to display a second machine-discernable image during a second specified time interval.
- Providing instructions for and wirelessly transmitting the second visual symbol information to the device for display after the first interval expires.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendants’ "SafeTix" technology, as implemented in systems such as the Ticketmaster mobile application (Compl. ¶¶1, 42).
Functionality and Market Context
- The complaint alleges that SafeTix replaces static barcodes on electronic tickets with a "constantly refreshing and encrypted barcode" (Compl. ¶38). This feature is marketed as a security measure that provides "unparalleled protection" against fraud by using a "rotating barcode that changes every few minutes," which prevents entry using screenshots or forged tickets (Compl. ¶¶39, 40, 43). The complaint presents a screenshot from the Ticketmaster app showing a digital ticket with a barcode and the warning, "Screenshots won't get you in" (Compl. p. 13). This feature is allegedly a "key component" of Defendants' mobile strategy and is described as instrumental in tackling fraudulent tickets (Compl. ¶¶30, 39).
IV. Analysis of Infringement Allegations
’715 Patent Infringement Allegations
| Claim Element (from Independent Claim 19) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| associating at a credential administration server a first portable electronic device, identifiable by a unique identifier, with a first user... | Defendants' system associates a user with their portable electronic device using a "Device ID," which is defined as a "unique identifier specific to [a] device/app install." | ¶42 | col. 10:54-58 |
| obtaining first visual symbol information, at the credential administration server, for use by the first portable electronic device in initiating display of a first machine discernable image...during a first specified time interval... | SafeTix allegedly obtains visual symbol information at its server to generate a "rotating barcode that changes every few minutes," which serves as the first image for the first time interval. The complaint provides a screenshot showing such a ticket with a barcode (Compl. p. 15). | ¶43 | col. 10:58-65 |
| wirelessly transmitting the first visual symbol information to the first portable electronic device... | SafeTix tickets are "delivered directly to fans' mobile devices through the app or via SMS or email." The system passes an "encrypted token" to the app to render the ticket. | ¶44 | col. 12:49-54 |
| obtaining second visual symbol information, at the credential administration server, for use by the first portable electronic device in initiating display of a second machine discernable image...during a second specified time interval... | Because the barcode rotates every few minutes, the system necessarily obtains second visual symbol information to generate the second, different barcode for the subsequent time interval. | ¶45 | col. 11:3-11 |
| wirelessly transmitting the second visual symbol information to the first portable electronic device. | The system allegedly initiates wireless transmission of the second visual symbol information to render the new barcode after the first time interval has passed. | ¶46 | col. 12:49-54 |
Identified Points of Contention
- Scope Questions: The infringement analysis may raise the question of whether the "encrypted token" transmitted by Defendants' system (Compl. ¶44) constitutes the "visual symbol information" as recited in the claims, or if the visual information is instead generated locally on the device based on the token. The claim language requires the server to "obtain" the "visual symbol information" for display.
- Technical Questions: A potential point of dispute is whether Defendants' server architecture, which may be a distributed, cloud-based system, meets the "credential administration server" limitation as understood in the context of the patent's specification and figures.
V. Key Claim Terms for Construction
The Term: "obtaining...visual symbol information, at the credential administration server"
- Context and Importance: This term is critical because the infringement theory depends on what the server does. If the server merely obtains an encrypted data packet (a "token") that the mobile app then interprets to create the barcode, Defendants may argue the server itself did not "obtain" the "visual symbol information." If, however, the token is considered to be or contain that information, it may support Plaintiff's theory.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not narrowly define how the information must be obtained or formatted. Language describing the server's role in choosing and "pushing" a "series of visual symbols" to devices could support a view where providing the data necessary to render the symbol is sufficient (’715 Patent, col. 8:37-40).
- Evidence for a Narrower Interpretation: The patent's flow chart in Figure 6 shows a step where the system "obtain[s] and transmit[s] [a] new computer readable visual symbol," which could imply the server handles the symbol itself, not just a precursor token (’715 Patent, Fig. 6, element 90).
The Term: "machine discernable image"
- Context and Importance: Practitioners may focus on this term because while the complaint shows barcodes, the term itself is broader. The definition will determine if other forms of dynamic credentials fall within the claim scope. The dispute may turn on whether the "constantly refreshing and encrypted barcode" of SafeTix is the "image" contemplated by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines "visual symbol" to "encompass machine readable bar codes (e.g. UPC codes), alphanumeric sequences..., images, and any other distinctive visible indicia" (’715 Patent, col. 6:38-44). This broad definition suggests the "image" is not limited to a specific format.
- Evidence for a Narrower Interpretation: The embodiments and examples focus heavily on barcodes and visual symbols that are directly displayed. Defendants may argue that the term requires a simple visual representation, potentially excluding more complex, encrypted data structures that are only rendered as an image at the last moment on the device.
VI. Other Allegations
- Indirect Infringement: The complaint alleges Defendants induce infringement by providing the Ticketmaster mobile application and actively encouraging and instructing customers and end users to use the SafeTix functionality in a manner that directly infringes the ’715 Patent (Compl. ¶49).
- Willful Infringement: The complaint alleges that Defendants had pre-suit knowledge of the asserted patent technology as early as November 2011, based on an email exchange between the patent's inventor and a Live Nation executive (Compl. ¶¶26-28, 48). The complaint alleges that despite this notice, Defendants launched the accused SafeTix product in 2019 and continued their conduct, suggesting the infringement was knowing, intentional, and willful (Compl. ¶48).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term "obtaining visual symbol information," as described in the context of the 2011-priority patent, be construed to cover the accused system’s method of transmitting an "encrypted token" that a mobile application uses to render a rotating barcode?
- A central evidentiary question will be one of pre-suit knowledge: what was the extent of the technical information disclosed in the alleged 2011 communication between the inventor and the Live Nation executive, and can that knowledge be imputed to the Defendants for the purpose of establishing willful infringement?
- A key technical question will be one of architectural mapping: does the potentially distributed, cloud-based nature of the modern SafeTix backend system correspond to the "credential administration server" limitation, which is depicted in the patent as a more centralized component?