2:25-cv-01111
Dynamuse LLC v. Idagio GmbH
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: DynaMuse LLC (New Mexico)
- Defendant: IDAGIO GmbH (Germany)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 2:25-cv-1111, E.D. Tex., 11/06/2025
- Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas on the basis that the defendant is a foreign corporation.
- Core Dispute: Plaintiff alleges that Defendant’s online media products infringe a patent related to mechanisms for searching, managing, and sharing media content across multiple online platforms and communities.
- Technical Context: The technology at issue addresses the management of digital media, such as music playlists, in an environment where user content is often stored across multiple, distinct online services.
- Key Procedural History: The complaint does not allege any prior litigation, licensing history, or other significant procedural events involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2012-02-29 | ’646 Patent - Earliest Priority Date |
| 2015-11-05 | ’646 Patent - Application Filing Date |
| 2019-11-26 | ’646 Patent - Issue Date |
| 2025-11-06 | Complaint Filing Date |
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"
- Issued: November 26, 2019.
The Invention Explained
- Problem Addressed: The patent background identifies a limitation in conventional systems regarding the control and ease users have in organizing and accessing audio/video files stored across various online media communities (U.S. Patent No. 10,491,646, col. 1:47-54). A specific example provided is the difficulty a user faces in determining which of their many playlists contain a particular song without having to manually search through each one individually (’646 Patent, col. 2:58-64).
- The Patented Solution: The invention is described as a method and system for "playlist assistance" that automates this discovery process (’646 Patent, col. 2:55-56). A central server receives a request from a user's device relating to specific media content, researches a "plurality of media playlists at a plurality of media communities" for that content, selects the playlists that contain it, and transmits the results back to the user's device (’646 Patent, Abstract; col. 2:21-33). The process is depicted in a flowchart in Figure 3A, showing the steps of receiving a request, processing it, researching playlists, sorting the results, and transmitting them to the client device.
- Technical Importance: The described technology aims to solve the problem of media library fragmentation by providing a unified interface for users to search their content across disparate online services and social networks (’646 Patent, col. 1:47-54).
Key Claims at a Glance
The complaint does not identify any specific claims of the ’646 Patent asserted against the Defendant. Instead, it refers to "Exemplary '646 Patent Claims" that are "identified in the charts incorporated into this Count" via an external exhibit not attached to the pleading (Compl. ¶11, ¶16).
III. The Accused Instrumentality
Product Identification
The complaint does not name any specific accused products or services. It refers generally to "Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')" (Compl. ¶11). These charts are part of Exhibit 2, which was not filed with the complaint (Compl. ¶14, ¶16).
Functionality and Market Context
The complaint provides no description of the functionality of the accused products. Its allegations are conclusory, stating that the "Exemplary Defendant Products practice the technology claimed by the '646 Patent" (Compl. ¶16). No specific features, modes of operation, or technical details of the accused products are described in the body of the pleading.
IV. Analysis of Infringement Allegations
The complaint references claim charts in an external "Exhibit 2" to support its infringement allegations but does not include this exhibit with the pleading (Compl. ¶16-17). The narrative infringement theory presented in the complaint asserts that the Defendant's products directly infringe the ’646 Patent by practicing the claimed technology (Compl. ¶16). The complaint also alleges that direct infringement occurs when Defendant's employees internally test and use the accused products (Compl. ¶12). Without the asserted claims or the claim charts, a detailed analysis of the infringement theory is not possible based on the provided documents.
No probative visual evidence provided in complaint.
Identified Points of Contention
- Scope Questions: A foundational question will concern whether the accused products, presumably related to Defendant's music streaming service, operate across a "plurality of media communities" as described in the patent, or if their functionality is limited to a single, proprietary ecosystem.
- Technical Questions: A primary evidentiary hurdle for the Plaintiff will be to demonstrate, with technical evidence, how the specific functions of the accused products map to the limitations of the asserted claims. The complaint's lack of detail raises the question of what specific features are alleged to perform the patented method of receiving a request, researching external playlists, and transmitting sorted results.
V. Key Claim Terms for Construction
The complaint does not identify specific asserted claims or disputed claim terms, precluding an analysis of key terms for construction.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells its products to customers and distributes "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶14). The complaint references the non-provided Exhibit 2 as containing evidence to support this allegation (Compl. ¶14).
- Willful Infringement: The complaint alleges post-suit willfulness. It asserts that the filing of the complaint provides Defendant with "actual knowledge of infringement" and that any continued infringing activity thereafter is willful (Compl. ¶13-14). No facts supporting pre-suit knowledge are alleged.
VII. Analyst’s Conclusion: Key Questions for the Case
- A threshold issue will be one of pleading sufficiency: does the complaint’s failure to identify asserted claims, accused products, or a factual basis for infringement in the pleading itself—relying instead on an external, unattached exhibit—satisfy the plausibility standard required to proceed with the case?
- Should the case move forward, a core technical question will be one of operational scope: does the accused IDAGIO service perform the claimed method of researching and aggregating media from a "plurality of media communities," or is its functionality confined to content within its own platform, potentially creating a mismatch with the patent's teachings on cross-community interaction?