Dynamuse LLC v. Xandrie SA

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DynaMuse LLC (New Mexico)
  • Defendant: Xandrie S.A. (France)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01114, E.D. Tex., 11/06/2025
• Venue Allegations: Venue is asserted on the basis that the defendant is a foreign corporation, and that acts of infringement occurred in the district, causing harm to the Plaintiff there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems for searching and organizing media content across multiple online playlists and communities.
• Technical Context: The technology addresses the management of digital media, specifically enabling users to find all playlists that contain a particular song, artist, or genre, a common challenge in an era of fragmented digital music libraries and streaming services.
• Key Procedural History: No prior litigation, licensing history, or other procedural events are mentioned in the complaint.

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 a limitation in conventional systems where users storing media files in various online communities have limited control and ease in organizing and searching their files across different playlists (’646 Patent, col. 1:42-53). A user who forgets which playlists contain a specific song has no efficient way to find them without manually checking each one (’646 Patent, col. 2:60-64).
• The Patented Solution: The invention provides a "playlist assistance" mechanism that, upon a user's request related to a specific media item (e.g., a song), can research multiple media playlists across various communities to find and display all playlists that contain that item (’646 Patent, Abstract; col. 2:21-31). As illustrated in the patent's transaction sequences, a server receives a request from a client device, researches playlists based on that request, sorts the results, and transmits the list of relevant playlists back to the user's device (’646 Patent, Fig. 3A).
• Technical Importance: This technology aims to unify a user's media experience across disparate services, addressing the fragmentation of digital content libraries by providing a centralized search and discovery tool. (Compl. ¶9).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," including "exemplary claims" identified in an attached exhibit, but does not specify any particular claims in the body of the complaint (Compl. ¶11, ¶16). Independent claim 1 is the broadest independent claim.
• Independent Claim 1 Elements:
  • A computer-implemented method performed by a media management device.
  • Facilitating the display of an interactive user interface while playing a media item (audio or video).
  • Facilitating the selection of a "playlist assistance function" via the user interface.
  • The playlist assistance function facilitates locating, identifying, and displaying results based on search criteria.
  • The results are "exactly matched" with search categories and other contents of the search criteria.
  • The results include one or more playlists classified as a "final output without any recommendations or suggestions."
  • The playlists include media items that "coincide" with the search categories.
  • The processing device refreshes results and other information (e.g., user identifications, artist data, social media webpage).
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, referring to them only as "Exemplary Defendant Products" identified in charts incorporated by reference as Exhibit 2. (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint alleges that the "Exemplary Defendant Products" practice the technology claimed by the ’646 Patent (Compl. ¶16). However, the complaint does not provide sufficient detail for analysis of the specific functionality of the accused products, as these details are contained within the unprovided Exhibit 2. (Compl. ¶17). No allegations regarding the products' market positioning are included.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from Exhibit 2, which was not provided with the complaint document. Therefore, a claim chart summary cannot be constructed. The complaint's narrative theory is that the Defendant's "Exemplary Defendant Products" practice the patented technology and "satisfy all elements of the Exemplary '646 Patent Claims" (Compl. ¶16). The complaint alleges direct infringement through the making, using, offering to sell, selling, and/or importing of these products, as well as through internal testing by Defendant's employees (Compl. ¶11-12).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question may be the scope of "playlist assistance function." The analysis will depend on whether the accused functionality is a distinct, selectable feature as described in the patent, or a more general search capability.
• Technical Questions: The claim requirement that results be "exactly matched" and presented as a "final output without any recommendations or suggestions" may be a key point of dispute. The case may turn on evidence of whether the accused products perform a simple query-and-return function as claimed, or if they include algorithmic suggestions, recommendations, or fuzzy matching that would fall outside the claim scope.

V. Key Claim Terms for Construction

• The Term: "playlist assistance function" (Claim 1)

  • Context and Importance: This term defines the core novel feature of the invention. Its construction will be critical to determining whether the accused products' search or discovery features fall within the scope of the claims. Practitioners may focus on whether this term requires a specific, branded software module (like the "PlaylistAssist®" mark mentioned in the patent at col. 4:2) or can read on any general search feature that identifies playlists.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The detailed description refers to the invention more generally as a "mechanism" that "facilitates playlist assistance" and can locate and identify playlists, suggesting the function is the key, not the specific name or implementation (’646 Patent, col. 2:21-26, col. 4:14-22).
    • Evidence for a Narrower Interpretation: The patent repeatedly refers to a specific "Playlist Assist Software" and shows it as a distinct, selectable option in user interface diagrams, which could support an argument that the "function" must be implemented as a discrete, user-selectable tool rather than an integrated, general-purpose search bar (’646 Patent, col. 1:12-16; Fig. 4L).

• The Term: "exactly matched" (Claim 1)

  • Context and Importance: This term qualifies the nature of the search results. Infringement may hinge on whether the accused products' search algorithms return only results that are a perfect match for the query (e.g., text string) or if they employ broader, relevance-based algorithms that would not be "exactly matched."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not explicitly define the term, which could allow for an argument that it means functionally exact (i.e., correctly identifying the specified song or artist) rather than requiring a literal string match.
    • Evidence for a Narrower Interpretation: The claim language distinguishes the "exactly matched" final output from systems that provide "recommendations or suggestions," implying the invention is intended to be a literal, non-interpretive search tool (’646 Patent, col. 21:12-14). This suggests a narrow, precise meaning for "exactly matched."

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to use the accused products in a manner that infringes the ’646 Patent (Compl. ¶14-15). The complaint notes these materials are referenced in Exhibit 2.
• Willful Infringement: The complaint does not allege pre-suit knowledge. It asserts that the filing and service of the complaint itself provides Defendant with "actual knowledge of infringement" and that any continued infringement would be willful (Compl. ¶13-14).

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

• A core issue will be one of factual proof: given the complaint's reliance on an unprovided exhibit, the initial phase of litigation will focus on discovering the precise technical operation of the "Exemplary Defendant Products" to determine if they perform the functions required by the patent claims.
• A key legal question will be one of definitional scope: can the term "playlist assistance function" be construed broadly to cover general media search features, or is it limited to a discrete, selectable software tool as depicted in the patent's specific embodiments?
• A central technical question will be one of algorithmic function: does the accused system's search functionality return results that are "exactly matched" and presented "without any recommendations," or does it incorporate modern search heuristics (like fuzzy matching, relevance ranking, or suggestions) that may place its operation outside the literal scope of the claims?