Dynamuse LLC v. Mixcloud Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DynaMuse LLC (New Mexico)
  • Defendant: Mixcloud Ltd. (United Kingdom)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01112, E.D. Tex., 11/06/2025
• Venue Allegations: Venue is alleged to be proper because the defendant is a foreign corporation, and the defendant has allegedly committed acts of patent infringement and caused harm in the district.
• Core Dispute: Plaintiff alleges that Defendant’s online media platform infringes a patent related to searching for and sharing media content across multiple online communities.
• Technical Context: The technology addresses the challenge of discovering and managing media, such as music playlists, that is stored across different, often incompatible, online social networks and media services.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

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

• Patent Identification: 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 (’646 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section notes that while individuals increasingly use various online media communities to store and access audio/video files, conventional systems are limited in the control and ease they offer for organizing and searching those files across different platforms (’646 Patent, col. 1:47-53).
• The Patented Solution: The invention provides a centralized mechanism, described as a "playlist assistant," that can receive a user request for specific media content (e.g., a song), research multiple media playlists across a plurality of different online media communities to find that content, and then transmit the located playlists back to the user's device (’646 Patent, Abstract; col. 2:20-33). This process is designed to eliminate the "laborious method of manually going through each and every playlist to find the media content" (’646 Patent, col. 4:14-29).
• Technical Importance: The technology purports to offer a unified discovery layer on top of otherwise siloed media ecosystems, allowing users to find content regardless of which specific community or service it resides on (’646 Patent, col. 2:35-40).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" and "the Exemplary '646 Patent Claims" (Compl. ¶11). However, it does not identify any specific asserted claims within the body of the complaint, instead referring to claim charts provided in an external "Exhibit 2" (Compl. ¶16). This exhibit was not provided.

III. The Accused Instrumentality

Product Identification

• The complaint does not name a specific accused product in its text. It refers to "the Defendant products identified in the charts" and "Exemplary Defendant Products" (Compl. ¶11, ¶16). As the defendant is Mixcloud Ltd., the accused instrumentality is presumably its online audio streaming service.

Functionality and Market Context

• The complaint does not provide a technical description of the accused products' functionality. It alleges generally that the "Exemplary Defendant Products practice the technology claimed by the '646 Patent" (Compl. ¶16). No allegations regarding the products' specific commercial importance or market positioning are included.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim charts in "Exhibit 2," which was not provided (Compl. ¶17). As the specific asserted claims and the corresponding accused functionalities are not detailed in the complaint itself, a claim chart summary cannot be constructed.

The narrative infringement theory alleges that Defendant directly infringes, either literally or under the doctrine of equivalents, by making, using, offering to sell, selling, and/or importing the accused products (Compl. ¶11). The complaint further alleges that the products "satisfy all elements of the Exemplary '646 Patent Claims" (Compl. ¶16). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: Without the asserted claims, a primary question will be which specific claim limitations are at issue. A potential dispute may center on the scope of terms like "researching a plurality of media playlists at a plurality of media communities" (’646 Patent, Abstract) and whether the accused service's functionality meets this multi-platform requirement as described in the patent.
  • Technical Questions: A central technical question will be what evidence demonstrates that the accused Mixcloud service performs the claimed steps. For example, does the service actively "research" external, third-party media communities for content as described in the patented solution, or does it operate primarily within its own content ecosystem?

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of key claim terms, as the asserted claims are not identified in the document.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct and encourage end users to use the accused products in a manner that directly infringes the ’646 Patent (Compl. ¶14-15).
• Willful Infringement: The basis for willfulness is alleged to be post-suit knowledge. The complaint asserts that service of the complaint and its attached claim charts "constitutes actual knowledge of infringement" and that Defendant's continued alleged infringement thereafter is willful (Compl. ¶13-14).

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

1. Pleading Sufficiency: A threshold issue may be whether the complaint, which outsources the identification of asserted claims and accused products to an external exhibit, meets the plausibility standards required for patent infringement pleadings. The lack of specific factual allegations mapping product features to claim elements in the complaint body itself could become a focus of early motion practice.
2. The "Cross-Community" Requirement: A core technical question will likely be whether the accused service performs the central function of the invention: "researching... a plurality of media communities" (’646 Patent, Abstract). The case may turn on evidence of whether the accused platform searches for and aggregates playlists from distinct, third-party online services, or whether its search functionality is limited to its own platform.
3. Knowledge and Intent: For the indirect and willful infringement claims, a key question will be what evidence demonstrates Defendant's knowledge and specific intent to encourage infringement. The allegation rests entirely on post-suit notice, raising the question of what actions Defendant took or failed to take after receiving the complaint that would support a finding of willfulness or inducement.