Muvox LLC v. Meta Platforms Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Muvox LLC (NM)
  • Defendant: Meta Platforms, Inc. (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00079, W.D. Tex., 06/09/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains an established place of business in the District and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unnamed products and services infringe a patent related to systems for categorizing music tracks based on acoustic attributes to create and stream customized playlists.
• Technical Context: The technology at issue addresses methods for automatically analyzing and classifying music to enable personalized, non-programmatic streaming, a core function in modern digital music services.
• Key Procedural History: The complaint is a First Amended Complaint, superseding an Original Complaint reportedly filed on February 19, 2025. This earlier filing date is cited as the basis for Defendant's alleged actual knowledge of the patent-in-suit.

Case Timeline

Date	Event
2014-03-27	U.S. Patent No. 11,899,713 Priority Date
2023-01-05	Application for U.S. Patent No. 11,899,713 Filed
2024-02-13	U.S. Patent No. 11,899,713 Issued
2025-02-19	Original Complaint Allegedly Filed
2025-06-09	First Amended Complaint Filed

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

U.S. Patent No. 11,899,713 - "Music streaming, playlist creation and streaming architecture"

• Patent Identification: U.S. Patent No. 11,899,713, "Music streaming, playlist creation and streaming architecture," issued February 13, 2024.

The Invention Explained

• Problem Addressed: The patent’s background section describes a challenge for music publishers, such as radio stations or independent labels, who wish to stream their music catalogs to users in a customized way but find that large, third-party streaming services may not provide sufficient branding opportunities or generate adequate income (’713 Patent, col. 1:50-65).
• The Patented Solution: The invention proposes a system where music tracks are analyzed to derive objective "rhythm, texture and pitch (RTP) scores" ('713 Patent, col. 2:9-11). These scores and associated metadata, but not the audio files themselves, are stored in a universal database accessible to multiple music publishers ('713 Patent, col. 2:17-23). An end-user application, sponsored by a specific publisher, accesses the database via an API to create personalized playlists, ensuring that only tracks the sponsoring publisher is licensed to stream are made available ('713 Patent, col. 2:27-34). Figure 1 illustrates the process of creating a sample set of scored tracks, extracting low-level data, and determining RTP scores to map to moods ('713 Patent, Fig. 1).
• Technical Importance: This architecture enables entities with music rights to offer a branded, personalized streaming experience without the cost and complexity of developing and maintaining a full-scale streaming infrastructure ('713 Patent, col. 2:28-34).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" without specifying them (Compl. ¶11). Claim 1 is the first independent method claim.
• Claim 1 Elements:
  • A method for selecting a song, comprising:
  • selecting the song based on a computer-derived comparison between a representation of the song to known similarities in representations of other songs,
  • wherein the known similarities in representations of other songs is based at least in part on a human-trained machine using the representations of the other songs,
  • wherein the representation of the song is based on isolating and identifying frequency characteristics of the song,
  • wherein the representations of a plurality of the other songs are based on a human listening to each of the plurality of the other songs in order to isolate and identify frequency characteristics,
  • and wherein the selection is based on the similarity between one or more moods of the song and the one or more moods of the plurality of the other songs.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of the patent.

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products or services (Compl. ¶11). It refers generally to "Defendant products identified in the charts incorporated into this Count below (among the ‘Exemplary Defendant Products’)" (Compl. ¶11). However, the referenced charts in Exhibit 2 were not filed with the complaint.

Functionality and Market Context

• The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '713 Patent" (Compl. ¶16). Based on the patent's subject matter, the accused functionality would presumably involve Meta's systems for providing, categorizing, recommending, and creating playlists from libraries of music available on its platforms. The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functions or market context.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from an "Exhibit 2," which was not attached to the publicly filed document (Compl. ¶16, ¶17). As such, a detailed claim-chart analysis is not possible. The narrative infringement theory alleges that Defendant’s products directly infringe by "practic[ing] the technology claimed by the '713 Patent" (Compl. ¶16). This suggests an allegation that Meta's music-related features perform a method of song selection that involves a computer-derived comparison of frequency characteristics, based on a model trained by human input, to match songs by "mood," as recited in claims like Claim 1 of the ’713 Patent. The complaint also alleges infringement by Defendant's internal testing and use of the accused products (Compl. ¶12).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Technical Questions: A primary question will be whether Plaintiff can produce evidence that Defendant’s systems perform the specific steps recited in the claims. For example, what evidence does the complaint provide that Defendant's song selection is based on "isolating and identifying frequency characteristics" in a manner that maps to the patent's disclosure of using spectrograms and deriving "RTP scores"?
  • Scope Questions: The dispute may turn on whether Defendant's music recommendation and playlist generation algorithms fall within the scope of the patent's claims. For instance, does the "computer-derived comparison" required by Claim 1 read on the functionality of modern, general-purpose machine learning recommendation engines, or is it limited to the specific RTP-scoring methodology described in the patent's specification?

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a definitive analysis of claim construction disputes. However, based on the technology, certain terms in Claim 1 of the '713 Patent are central to the scope of the invention.

• The Term: "computer-derived comparison"
• Context and Importance: This term is the core of the claimed method. Its breadth will determine whether the claim covers any algorithmic matching of songs or is restricted to a more specific process. Practitioners may focus on this term because its construction will likely be dispositive of infringement.
  • Evidence for a Broader Interpretation: The plain language of the term itself does not specify a particular algorithm or method, which may support an interpretation covering any comparison performed by a computer.
  • Evidence for a Narrower Interpretation: The specification consistently describes the invention in the context of deriving and using "rhythm, texture and pitch (RTP) scores" ('713 Patent, Abstract; col. 2:9-11). An argument could be made that the "comparison" is limited to one based on this specific, disclosed methodology.
• The Term: "human-trained machine"
• Context and Importance: This limitation requires a specific origin for the system's analytical capability. The dispute will likely focus on what level and type of "human training" are required to satisfy the claim.
  • Evidence for a Broader Interpretation: The claim language does not specify the method or extent of training, potentially covering any machine learning model where human-labeled data was used at some stage of development.
  • Evidence for a Narrower Interpretation: The specification describes a specific training process where "tracks sufficient to create a sample set may be listened to by humans to develop RTP scores that correspond to each track" ('713 Patent, col. 4:36-39). This could support an argument that the claim requires a machine trained on a data set created through direct human listening and scoring for the specific purpose of the invention.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '713 Patent" (Compl. ¶14).
• Willful Infringement: The basis for the willfulness allegation is post-suit knowledge. The complaint asserts that service of the Original Complaint on February 19, 2025, constituted "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. Evidentiary Burden: A central challenge for the Plaintiff will be one of "proof": given the lack of specific factual allegations in the complaint, what evidence can be marshaled to demonstrate that Defendant’s non-public, internal software systems perform the specific steps of isolating frequency characteristics and using a "human-trained machine" for song comparison as required by the patent's claims?
2. Definitional Scope: The case will likely turn on a question of "claim construction": will the term "computer-derived comparison" be interpreted broadly to encompass a wide range of modern music recommendation algorithms, or will it be narrowed by the specification's detailed disclosure to the specific "RTP score" system, potentially placing Defendant's technology outside the claim's scope?
3. Pleading Sufficiency: An initial question for the court may be one of "procedural adequacy": does the complaint's reliance on general allegations and an unprovided exhibit meet the plausibility pleading standards for patent infringement, or will Defendant succeed in arguing that the allegations are too conclusory to proceed?