Dynamuse LLC v. Soundcloud Global Ltd & Co KG

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DynaMuse LLC (New Mexico)
  • Defendant: SoundCloud Global Limited & Co. KG (Germany)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01113, E.D. Tex., 11/06/2025
• Venue Allegations: Venue is asserted on the basis that the Defendant is a foreign corporation, making venue proper in any judicial district pursuant to 28 U.S.C. § 1391(c).
• Core Dispute: Plaintiff alleges that Defendant’s online media platform infringes a patent related to a system for playlist assistance and sharing media content across multiple online communities.
• Technical Context: The technology addresses methods for users to search for and manage media, such as songs, within playlists stored across various online services, a core functional area for digital music and video platforms.
• Key Procedural History: The complaint is the initial pleading in this matter and does not reference any prior litigation, licensing history, or administrative proceedings involving the patent-in-suit.

Case Timeline

Date	Event
2012-02-29	’646 Patent 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"

The patent-in-suit is U.S. Patent No. 10,491,646, issued November 26, 2019 (the "’646 Patent").

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty users face in managing their digital media files, specifically the inability of "conventional systems" to help a user find which of their many playlists contain a particular song without manually searching each one individually (’646 Patent, col. 1:47-53, col. 2:60-65).
• The Patented Solution: The invention provides a "playlist assistance" mechanism that allows a user to select a media item (e.g., a song) and then displays all playlists in the user's library that contain that item, based on criteria like song title, artist, or genre (’646 Patent, col. 2:55-65). This is designed to centralize and simplify the process of locating content spread across multiple playlists and communities (’646 Patent, col. 2:20-34). Figure 3A illustrates the core workflow of receiving a user request, researching playlists, sorting the results, and transmitting them to the user's device (’646 Patent, Fig. 3A).
• Technical Importance: The claimed solution addresses a user experience challenge that became more prevalent with the proliferation of cloud-based media services and user-generated playlists, where a user's collection of media may be fragmented across different platforms and lists (’646 Patent, col. 1:42-47).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying which ones (Compl. ¶11). Independent claim 1 is a representative method claim.
• Essential Elements of Independent Claim 1:
  • A computer-implemented method for facilitating user-controlled features in media communities.
  • Displaying an interactive user interface while a media item is playing.
  • Selecting a "playlist assistance function" via the user interface.
  • The function facilitates locating, identifying, and displaying results based on search criteria, where the results are "exactly matched" with the search categories.
  • The results are "classified as a final output without any recommendations or suggestions."
  • The results include a plurality of playlists having multiple sets of playlists offering different media items.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint accuses "Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')" (Compl. ¶11). It further states that these charts are included in Exhibit 2, which was not provided with the complaint document (Compl. ¶¶16-17). Given the defendant's identity, the accused instrumentality is understood to be the SoundCloud online audio distribution platform and its associated applications.

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed" by the ’646 Patent, which implies they incorporate functionalities for users to create, manage, search, and share media content and playlists (Compl. ¶16). The complaint does not provide specific details about the operation of the accused products, instead referring to the non-proffered claim chart exhibit. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or detailed infringement allegations in its body; it incorporates by reference an external "Exhibit 2" that was not included in the filing (Compl. ¶17). Therefore, a claim chart summary cannot be constructed.

The infringement theory, as stated in the complaint, is that the "Exemplary Defendant Products practice the technology claimed by the '646 Patent" and "satisfy all elements of the Exemplary '646 Patent Claims" (Compl. ¶16). This is a conclusory allegation that lacks specific factual support within the provided document.

• Identified Points of Contention:
  • Evidentiary Questions: The primary point of contention will be factual and evidentiary. What specific features of the SoundCloud platform allegedly perform each of the detailed steps recited in the asserted claims? The complaint provides no specific mapping of product functionality to claim elements.
  • Scope Questions: A central question may arise from the claim limitation requiring results that are "classified as a final output without any recommendations or suggestions" (’646 Patent, col. 21:13-15). The analysis will question whether a modern music streaming service, which typically integrates algorithmic recommendations, can be found to provide search results that are strictly devoid of such suggestions as required by the claim.

V. Key Claim Terms for Construction

• The Term: "playlist assistance function"

• Context and Importance: This term appears central to the invention, as it is the mechanism that performs the claimed locating, identifying, and displaying of results (’646 Patent, col. 21:4-8). Its construction will define the scope of the core technology protected by the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the function in general terms as a "media library playlist assistant" that helps locate playlists (’646 Patent, col. 4:14-23). This could support a construction covering a range of playlist search tools.
  • Evidence for a Narrower Interpretation: Claim 1 itself narrowly defines the function by its outputs, requiring that it produce results that are "exactly matched" and "without any recommendations or suggestions" (’646 Patent, col. 21:10-15). This language may support a construction limited to a tool that performs a literal, non-suggestive search.

• The Term: "exactly matched"

• Context and Importance: This term, used in Claim 1 to describe the relationship between the search results and the search criteria, suggests a high degree of precision is required (’646 Patent, col. 21:10-11). Practitioners may focus on this term because infringement could turn on whether the accused product's search results meet this strict standard or instead provide broader, "related" results.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of this element.
  • Evidence for a Narrower Interpretation: The plain meaning of "exactly" suggests no deviation from the search criteria is permitted, which could exclude results based on fuzzy logic, synonyms, or algorithmic associations common in modern search engines.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that allegedly infringes the ’646 Patent (Compl. ¶14).
• Willful Infringement: The complaint does not use the word "willful" but alleges that service of the complaint constitutes "actual knowledge of infringement" and that Defendant's subsequent infringing activities are done "despite such actual knowledge" (Compl. ¶¶13-14). These allegations form a basis for a claim of post-suit willful infringement.

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

• A key evidentiary question will be one of factual sufficiency: Can the Plaintiff produce evidence demonstrating that the accused SoundCloud platform performs every limitation of the asserted claims, particularly given the complaint’s reliance on a non-proffered exhibit and its lack of specific, element-by-element factual allegations?
• A core issue will be one of definitional scope: How will the court construe the negative limitation "without any recommendations or suggestions"? The case may turn on whether the functionality of a modern, algorithm-driven streaming service, which is often designed to provide user recommendations, can fall within the scope of a claim that appears to explicitly forbid such features in its output.