Dynamuse LLC v. Deezer SA

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DynaMuse LLC (New Mexico)
  • Defendant: Deezer SA. (France)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01110, E.D. Tex., 11/06/2025
• Venue Allegations: Plaintiff asserts that venue is proper in the district because the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s music streaming service infringes a patent related to searching for and managing media content across multiple online communities and playlists.
• Technical Context: The technology addresses the organization of digital media, specifically enabling users to locate all playlists containing a particular media item (e.g., a song) across various online sources.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history concerning the patent-in-suit. The patent-in-suit is a continuation of a prior U.S. patent application.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,491,646 - "Mechanism for facilitating user-controlled features relating to media content in multiple online media communities and networks"

The Invention Explained

• Problem Addressed: The patent background describes the difficulty users face in managing media files spread across numerous online communities and playlists. A specific problem noted is that when a user forgets which playlists contain a particular song, conventional systems offer no method to find those playlists without manually searching through each one individually (’646 Patent, col. 1:45-54, col. 2:60-65).
• The Patented Solution: The invention provides a system that receives a user request related to a specific media item, researches a plurality of media playlists across various media communities to find that item, and then transmits a list of the playlists containing the item back to the user’s device (’646 Patent, Abstract; col. 2:21-33). This process is depicted in a flowchart in Figure 3A, which shows the steps of receiving a request, researching playlists, obtaining and sorting the results, and transmitting them to the client device (’646 Patent, Fig. 3A).
• Technical Importance: The technology aimed to centralize and simplify the user experience for managing media libraries that had become fragmented across a growing number of separate online services and social networks (’646 Patent, col. 1:45-49).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying which ones (Compl. ¶11). Independent claim 1 is representative of the patented method.
• Essential elements of Independent Claim 1:
  • Displaying an interactive user interface while playing a media item.
  • Facilitating the selection of a "playlist assistance function" via the user interface.
  • The playlist assistance function locates, identifies, and displays results based on search criteria.
  • The results are "exactly matched" with search categories, and are a "final output without any recommendations or suggestions."
  • The results include playlists that contain media items coinciding with the search categories.
  • The search categories include at least one of a title, artist, album, or genre.
• The complaint reserves the right to assert other claims, which may include dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies "Defendant products" generally, with the defendant being DEEZER S.A., a digital music streaming service (Compl. ¶3, ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused product's specific functionality. It alleges that the "Exemplary Defendant Products practice the technology claimed by the '646 Patent" and incorporates by reference charts from an exhibit that was not attached to the publicly filed complaint (Compl. ¶16-17).

IV. Analysis of Infringement Allegations

The complaint alleges that the Defendant's products infringe the ’646 Patent and states that "Exhibit 2 includes charts comparing the Exemplary ’646 Patent Claims to the Exemplary Defendant Products" (Compl. ¶16). However, this exhibit was not provided with the filed complaint. The complaint’s narrative theory is that the accused products "satisfy all elements of the Exemplary ’646 Patent Claims" as demonstrated in the unattached charts (Compl. ¶16). No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the language of the asserted patent and the general nature of the accused service, several points of contention may arise.

• Scope Questions: Claim 1 requires the selection of a distinct "playlist assistance function" (’646 Patent, col. 21:5-6). A potential dispute is whether the Defendant’s standard search feature can be construed as this specific function, especially as the patent specification depicts a "PlaylistAssist" feature as a discrete menu option (’646 Patent, Fig. 4L, item 484).
• Technical Questions: Claim 1 requires that the displayed results are a "final output without any recommendations or suggestions" (’646 Patent, col. 21:13-15). A central question may be whether the accused service, which may employ algorithms to rank or supplement search results, provides an output that meets this negative limitation.

V. Key Claim Terms for Construction

"playlist assistance function"

• Context and Importance: The definition of this term is central, as it describes the core mechanism that a user must select to initiate the claimed process. The dispute will likely focus on whether this term covers any general search that returns playlists or is limited to a specific, dedicated tool for that purpose.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes a "mechanism" that "facilitates playlist assistance that displays every playlist that includes any particular or selected file or track" (’646 Patent, col. 2:55-58). This language could support an argument that the function itself, rather than its specific name or implementation, is what matters.
  • Evidence for a Narrower Interpretation: The specification includes figures showing a user interface with a button explicitly labeled "PlaylistAssist" (’646 Patent, Fig. 4L, item 484). Furthermore, the patent refers to "Playlist Assist®" software, suggesting a specific, branded feature rather than a generic capability (’646 Patent, col. 4:2).

"final output without any recommendations or suggestions"

• Context and Importance: This negative limitation is critical to defining the scope of infringement. Many modern search systems provide algorithmically-generated content, such as related artists or suggested songs, alongside direct results. Whether the accused product’s output is "without" such content will be a key factual question.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of this term.
  • Evidence for a Narrower Interpretation: The plain language of the claim appears to create a strict requirement. The patent describes a direct, unfiltered result: a list of "all playlists having the requested song" (’646 Patent, col. 5:6-8). This may support an interpretation that the output must be limited exclusively to playlists that meet the exact search criteria.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use its products in a manner that infringes the ’646 Patent (Compl. ¶14).

Willful Infringement

The allegation of willfulness is based on post-suit knowledge. The complaint asserts that the "service of this Complaint... constitutes actual knowledge of infringement" and that Defendant continues its allegedly infringing activities despite this knowledge (Compl. ¶13-14).

VII. Analyst’s Conclusion: Key Questions for the Case

• A core issue will be one of definitional scope: Does a general-purpose search feature in a modern streaming service constitute the specific "playlist assistance function" claimed in the ’646 Patent, or does the patent’s language and figures limit the claim to a more specialized tool?
• A key evidentiary question will be one of factual compliance: Can the Plaintiff demonstrate that the accused service provides a "final output without any recommendations or suggestions," as strictly required by Claim 1, or do the service's search results inherently include algorithmic content that falls outside the claim’s scope?