DynaMuse LLC v. Audiomack Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DynaMuse LLC (New Mexico)
  • Defendant: Audiomack Inc. (Delaware)
  • Plaintiff's Counsel: Silverman, McDonald & Friedman
• Case Identification: 1:26-cv-01125, D. Del., 09/04/2026
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the defendant is incorporated in Delaware, has an established place of business in the district, has allegedly committed acts of infringement there, and the plaintiff has suffered harm in the district.
• Core Dispute: Plaintiff alleges that Defendant's music streaming service infringes a patent related to methods for searching and organizing media content within and across multiple playlists.
• Technical Context: The technology at issue pertains to the organization and retrieval of digital media files, a core user experience element in the competitive music and video streaming market.
• 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

Date	Event
2012-02-29	'646 Patent Priority Date
2019-11-26	'646 Patent Issue Date
2026-09-04	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 Invention Explained

• Problem Addressed: The patent's background section identifies a limitation in conventional systems where users cannot easily determine which of their numerous playlists contain a specific song or media file without manually searching through each playlist individually '646 Patent, col. 2:60-65
• The Patented Solution: The invention is a "playlist assistance" mechanism that, when activated, can search a user's media library and display a comprehensive list of all playlists that contain a particular selected item (e.g., a song), or items matching certain criteria (e.g., by the same artist or in the same genre) '646 Patent, col. 2:55-60 The system is described as researching media playlists across a plurality of media communities and transmitting the sorted results to the user's device '646 Patent, abstract '646 Patent, FIG. 3A
• Technical Importance: The patented technology aims to provide a unified search and organization tool to help users manage media collections that may be fragmented across various online services and platforms.

Key Claims at a Glance

• The complaint does not specify which claims of the '646 Patent are asserted, instead referring to "Exemplary '646 Patent Claims" identified in an unprovided exhibit Compl. ¶11 Compl. ¶16 Independent claim 1 is analyzed here as a representative claim.
• The essential elements of independent claim 1, a method claim, include:
  • Facilitating the display of an interactive user interface while a media item is playing.
  • Facilitating the selection of a "playlist assistance function" via the user interface.
  • The playlist assistance function locates, identifies, and displays results based on search criteria, where the results are "exactly matched" with search categories prior to display.
  • The results are classified as a "final output without any recommendations or suggestions."
  • The function involves a processing device that refreshes results and other information, including "user identifications, shared user identifications, artist data, themes, a social media webpage associated with a user, and the one or more playlists."
  • The selection of the function facilitates the performance of tasks, such as interactively displaying multiple sets of playlists.

III. The Accused Instrumentality

Product Identification

The complaint does not explicitly name the accused product(s), referring to them as the "Exemplary Defendant Products" Compl. ¶11 As the defendant is Audiomack Inc., the accused instrumentality is understood to be the Audiomack music streaming service, including its associated applications and websites.

Functionality and Market Context

The complaint does not provide a functional description of the accused products. Instead, it alleges that the products' infringing nature is detailed in claim charts provided as Exhibit 2, which was not included with the complaint document Compl. ¶16 Compl. ¶17 The complaint alleges that Defendant makes, uses, sells, and imports these products in the United States Compl. ¶14

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from an unprovided "Exhibit 2" to support its infringement allegations Compl. ¶16 Compl. ¶17 As the charts are not available, a table cannot be constructed. The complaint's narrative theory 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 Based on the technology of the '646 Patent, the infringement allegation likely targets a feature within the Audiomack service that enables users to search for and identify playlists containing a specific song, artist, or other media characteristic.

• Identified Points of Contention:
  • Scope Questions: The infringement analysis may raise the question of whether the term "final output without any recommendations or suggestions" as used in the patent can be read to cover a modern search results page, which often includes related or algorithmically generated content alongside direct results '646 Patent, col. 21:13-14
  • Technical Questions: A key technical question is whether the accused Audiomack feature performs an "exactly matched" search as required by claim 1, or if it employs a more flexible, non-literal search algorithm '646 Patent, col. 21:10-12 Further, it is an open question what evidence will show that the accused service performs the complex "refresh" function recited in the claim, which includes updating based on a long list of data types such as "themes" and a "social media webpage associated with a user" '646 Patent, col. 21:21-23

V. Key Claim Terms for Construction

"playlist assistance function"

• Context and Importance: This term defines the core inventive concept. The construction of this term will be critical in determining whether any feature in the accused Audiomack service falls within the scope of the claims.
• Intrinsic Evidence for a Broader Interpretation: The specification describes the function's purpose broadly as a mechanism that "displays every playlist that includes any particular or selected file or track" from a library '646 Patent, col. 2:55-57
• Intrinsic evidence for a Narrower Interpretation: Claim 1 itself recites numerous specific limitations on this function, requiring it to produce a "final output without any recommendations or suggestions" and to facilitate results that are "exactly matched" with search criteria, suggesting a very specific and constrained operation '646 Patent, col. 21:8-24

"exactly matched"

• Context and Importance: This term is central to the nature of the search operation required by the claim. The dispute may turn on whether the accused service's search functionality is literal and exact, or if it is algorithmic and permits inexact or related results.
• Intrinsic Evidence for a Broader Interpretation: Parties could argue this term requires only that the core search criteria are met, not that the results are exclusively limited to those criteria.
• Intrinsic Evidence for a Narrower Interpretation: The claim's phrasing, particularly when read with the "without any recommendations or suggestions" limitation, suggests the patentee intended a strict, literal matching process where only results that precisely conform to the search categories are displayed '646 Patent, col. 21:10-14

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that the defendant knowingly encourages infringement by selling its products to customers and distributing "product literature and website materials" that instruct end users on how to use the products in an infringing manner Compl. ¶14 Compl. ¶15

Willful Infringement

The allegation of willfulness appears to be based on post-suit conduct. The complaint asserts that its service, along with the attached claim charts, provides Defendant with "actual knowledge of infringement" and that any continued infringement thereafter is willful Compl. ¶13 Compl. ¶14

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

• A core issue will be one of definitional scope: can the highly specific limitations of the asserted claims, such as requiring an "exactly matched" result and a "final output without any recommendations or suggestions," be construed to cover the features of a modern music streaming service that likely relies on complex algorithms and often presents recommended content alongside direct search results?
• A key evidentiary question will be one of technical equivalence: what evidence will the plaintiff present to demonstrate that the accused Audiomack product performs the specific, multi-part "refresh" function as recited in claim 1, which requires updating based on a long and varied list of data points including "themes" and "a social media webpage associated with a user"?
• The case may also bring the issue of patent eligibility to the forefront, as the detailed and specific limitations in the claims may become a focal point in arguments over whether the claims are directed to the patent-ineligible abstract idea of organizing information or to a specific, tangible improvement in computer functionality.