ScanComm v. Block, Inc.: § 101 Dismissal in Scannable Label Patent Case
What would you like to do next?
Choose your path based on your current needs:
📋 Case Summary
| Case Name | ScanComm, LLC v. Block, Inc. |
| Case Number | 1:24-cv-00867 (N.D. Ga.) |
| Court | U.S. District Court for the Northern District of Georgia |
| Duration | Feb 2024 – Mar 2025 1 year 1 month |
| Outcome | Defendant Win – Dismissed with Prejudice (§ 101) |
| Patent at Issue | |
| Accused Products | Block, Inc.’s product ecosystem (e.g., Square POS) |
Case Overview
The Parties
⚖️ Plaintiff
Patent holder of a communication system built around scannable labels, targeting broad commercial applications in retail, logistics, and marketing.
🛡️ Defendant
Fintech and commerce technology company (formerly Square) offering hardware and software facilitating POS, merchant services, and digital payments.
The Patent at Issue
U.S. Patent No. 11,003,878 B2 describes a system for enabling user-to-publisher communication via scannable labels, a concept with applications in customer engagement and interactive marketing.
- • US 11,003,878 B2 — System enabling user-to-publisher communication via scannable labels
Developing scan-based technology?
Check if your system might infringe or face similar § 101 challenges.
The Verdict & Legal Analysis
Outcome
The U.S. District Court for the Northern District of Georgia granted Block, Inc.’s motion to dismiss, finding ScanComm’s claims directed to patent-ineligible subject matter under 35 U.S.C. § 101. The case was **dismissed with prejudice**, representing a complete defense victory for Block, Inc. at the pleadings stage.
Key Legal Issues
The court’s analysis centered on the **Alice/Mayo framework** for patent eligibility. The dismissal indicates the court found the claims directed to an abstract idea (facilitating communication via scannable labels) without providing a sufficiently inventive technical solution to transform the abstract idea into patent-eligible subject matter.
Drafting patents for scan-based tech?
Learn from this case. Use AI to draft stronger, eligibility-resilient claims.
Power Your Patent Strategy with Eureka IP
From novelty searches to patent drafting, Eureka’s AI-powered tools help you navigate the patent landscape with confidence.
⚠️ Freedom to Operate (FTO) & Eligibility Analysis
This case highlights critical § 101 risks in scan-based communication. Choose your next step:
📋 Understand This Case’s Impact
Learn about the specific § 101 risks and implications from this litigation.
- View related § 101 case law and abstract idea rulings
- See common abstract ideas in scan-based technology patents
- Understand eligibility challenges at the motion to dismiss stage
🔍 Check My Product’s Risk
Run a comprehensive FTO & eligibility analysis for your own technology or product.
- Input your product description or technical features
- AI identifies potentially blocking patents & abstract ideas
- Get actionable risk assessment report
High Risk Area
Broadly functional communication systems
Ongoing § 101 Scrutiny
For scan-based tech & digital interfaces
Clearer Drafting Needed
To avoid abstract idea findings
✅ Key Takeaways
For Patent Attorneys
§ 101 motions to dismiss remain powerful tools; Block’s win at the pleadings stage avoided costly discovery and claim construction.
Search related case law →Dismissal with prejudice carries maximum defensive value — pursue it when eligibility defects are clear from the patent’s face.
Explore precedents →ScanComm’s loss illustrates the risk of asserting patents with broadly functional claims in scan/communication technology spaces.
Review claim drafting strategies →For R&D Teams
FTO analyses in QR code, scannable label, and user-publisher communication spaces should flag § 101 vulnerability as a distinct risk factor.
Start FTO analysis for my product →Invest in patent prosecution strategies that capture genuine technical innovations at the implementation level, not just functional outcomes.
Try AI patent drafting →Ready to Strengthen Your Patent Strategy?
Join thousands of IP professionals using Eureka to conduct prior art searches, draft patents, and analyze competitive landscapes.