DynaMuse LLC v. Iheartmedia Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DynaMuse LLC (New Mexico)
  • Defendant: iHeartMedia, Inc. (Delaware)
  • Plaintiff's Counsel: Rabicoff Law LLC
• Case Identification: 7:26-cv-00116, W.D. Tex., 03/31/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains an established place of business within the district and has allegedly committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a mechanism for facilitating user-controlled features for media content, specifically a "playlist assistance" function that identifies playlists containing selected media.
• Technical Context: The technology addresses the organization and searching of media playlists within online music communities and social networks, a core feature for digital media consumption.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2012-02-29	U.S. Patent No. 10,491,646 Priority Date
2015-11-05	U.S. Patent No. 10,491,646 Application Filing Date
2019-11-26	U.S. Patent No. 10,491,646 Issue Date
2026-03-31	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"

• 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.

The Invention Explained

• Problem Addressed: The patent describes a problem where users who have created numerous media playlists find it difficult and laborious to determine which of those playlists contain a particular song or media file without manually searching through each one individually '646 Patent, col. 2:60-65
• The Patented Solution: The invention provides a "playlist assistance" mechanism that automates this process '646 Patent, col. 2:55-60 When a user selects a media item (e.g., a song), the system researches a plurality of media playlists and transmits to the user a list of playlists that contain that specific item, artist, or genre, solving the problem of manually searching '646 Patent, abstract '646 Patent, col. 5:54-64 This is illustrated in the transaction sequence where a user request for media content (302) leads to researching playlists (306) and transmitting sorted results back to the user (310) '646 Patent, Fig. 3A
• Technical Importance: The technology aims to improve user experience in digital media libraries by providing an efficient, cross-playlist search capability, a function of increasing importance as users' digital media collections grow. '646 Patent, col. 2:42-49

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying which ones Compl. ¶11 Independent claim 1 is representative of the core invention.
• Independent Claim 1 Elements:
  • A computer-implemented method for facilitating user-controlled features relating to media content.
  • Displaying an interactive user interface while playing a media item at a media-enabled computing device.
  • Facilitating the selection of a "playlist assistance function" via the user interface.
  • The function facilitates locating, identifying, and displaying results based on search criteria.
  • The results are "exactly matched" with search categories and other search criteria contents.
  • The results are a "final output without any recommendations or suggestions."
  • The results include one or more playlists containing media items that "coincide with the one or more search categories."
• The complaint does not explicitly reserve the right to assert dependent claims but refers to "exemplary claims" Compl. ¶11

III. The Accused Instrumentality

Product Identification

• The complaint identifies "Exemplary Defendant Products" but does not name specific products or services in the body of the complaint Compl. ¶11 The infringement allegations are detailed in an incorporated but unprovided exhibit Compl. ¶16 Compl. ¶17

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement by Defendant's products but relies entirely on claim charts in an external "Exhibit 2," which was not provided with the complaint Compl. ¶16 Compl. ¶17 The complaint asserts in a conclusory manner 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 No specific, element-by-element allegations are made in the body of the complaint itself.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: The complaint's lack of specificity raises the fundamental question of which products and features are actually accused.
  • Technical Questions: A central technical question will be whether the accused functionality returns results that are "exactly matched" and a "final output without any recommendations or suggestions," as required by claim 1, or if they include algorithmic suggestions, advertisements, or other content that would fall outside the claim scope.

V. Key Claim Terms for Construction

• The Term: "playlist assistance function"

• Context and Importance: This term appears to be a neologism central to the patent's claims and is the core of the asserted invention '646 Patent, claim 1 Its construction will define the scope of the patented solution and will be critical to determining whether any feature in the accused products meets this limitation. Practitioners may focus on this term because its definition is not plain and ordinary and is key to the infringement analysis.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the function broadly as a "mechanism" that "displays every playlist that includes any particular or selected file or track" according to criteria like song, artist, or genre '646 Patent, col. 2:55-60
  • Evidence for a Narrower Interpretation: The detailed description of the function involves specific steps of receiving a request, researching multiple media communities, selecting playlists, and transmitting the results back to the user '646 Patent, abstract A defendant may argue the term is limited to a function performing this specific sequence.

• The Term: "exactly matched"

• Context and Importance: This term in claim 1 qualifies the nature of the search results '646 Patent, claim 1 It is used in conjunction with the negative limitation "without any recommendations or suggestions." The interpretation of "exactly matched" will determine whether accused systems that provide algorithmically-related or suggested content in addition to direct matches fall within the claim's scope.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term is not explicitly defined, which may support an argument for its plain and ordinary meaning of a direct, one-to-one correspondence based on the search criteria.
  • Evidence for a Narrower Interpretation: The context provided by the negative limitation "without any recommendations or suggestions" suggests "exactly matched" must be interpreted narrowly to exclude any results that are not a literal match to the search query, thereby distinguishing the invention from recommendation engines '646 Patent, claim 1

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 '646 Patent" Compl. ¶14 It references an unprovided "Exhibit 2" for details Compl. ¶14 The allegations are based on knowledge acquired "at least since being served by this Complaint" Compl. ¶15
• Willful Infringement: The complaint does not contain a separate count for willful infringement, but the prayer for relief requests that the case be declared "exceptional" Compl., Prayer E(i) The basis for knowledge is post-suit, established by "the service of this Complaint, in conjunction with the attached claim charts" Compl. ¶13

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

1. Evidentiary Sufficiency: A threshold issue is the complaint's high-level, "notice pleading" style. A key question is whether the infringement theory, which relies entirely on an unprovided external exhibit, will be sufficient to move the case forward or if it will be challenged for lack of specificity regarding the accused products and the mechanism of infringement.
2. Definitional Scope: The case will likely hinge on the construction of key claim terms. A core issue will be one of definitional scope: can the term "playlist assistance function," as defined in the patent, be construed to cover the search and playlist-related features of a modern, large-scale commercial streaming service?
3. Functional Mismatch: A central technical question will be one of functional operation: do the accused products provide results that are "exactly matched... without any recommendations or suggestions," as strictly required by Claim 1, or do they incorporate algorithmic, promotional, or related content that places their functionality outside the claimed invention?