DynaMuse LLC v. Sirius XM Radio Inc.

I'll research this case across the docket, patent records, and litigation press.

Now let me pin down the patent itself and the broader DynaMuse campaign.

Case Overview — DynaMuse LLC v. Sirius XM Radio Inc., No. 3:26-cv-00803 (N.D. Tex.)

Parties and the plaintiff's assertion model. The complaint was filed March 12, 2026, in the Dallas Division of the Northern District of Texas (Dkt. 1), with a jury demand, and was initially assigned to Senior Judge David C. Godbey before being reassigned to Judge Ada Brown under Special Order 3; summons issued and the AO 120 notice was sent to the USPTO the same day (Dkt. 7, 8). Plaintiff DynaMuse LLC is a New Mexico limited liability company (per third-party complaint analysis of the parallel iHeartMedia action), and it is the sole named plaintiff — the docket's Rule 7.1 disclosure reflects no parent or affiliate (Dkt. 3, with a clerk QC note that no affiliate was entered). Although some aggregator pages tag DynaMuse as an "operating company," Stanford's NPE Litigation Database classifies DynaMuse as a non-practicing entity, and the surrounding filing pattern is consistent with that: DynaMuse has run a single-patent campaign against music-streaming and digital-radio platforms, filing against Deezer S.A. (2:25-cv-01110), SoundCloud Global (2:25-cv-01113), and Xandrie S.A. (2:25-cv-01114) in E.D. Tex. on November 6, 2025; then iHeartMedia, Inc. in W.D. Tex. (7:26-cv-00116, filed March 31, 2026); Sirius XM in N.D. Tex. (this case); and Songtradr, Inc. in D. Del. (1:26-cv-01123, filed September 4, 2026). The SoundCloud case was voluntarily dismissed with prejudice by stipulated order in January 2026 (S.D. Tex./E.D. Tex. docket entries 12–16) — a typical quick-settlement signature. Plaintiff's counsel of record is Isaac P. Rabicoff of Rabicoff Law LLC, who filed all of these suits. Defendant Sirius XM Radio Inc. is the satellite-radio broadcaster and, through Pandora and its streaming app, a major digital audio platform — an operating company with substantial exposure to playlist/station-discovery functionality.

The patent and the accused technology. The sole patent asserted is U.S. Patent No. 10,491,646, titled "Mechanism for facilitating user-controlled features relating to media content in multiple online media communities and networks." It issued November 26, 2019, from an application filed November 5, 2015, claiming priority to February 29, 2012 (so nominal expiration runs to about November 2035, absent terminal disclaimer or PTA). Technical sketch: the patent claims a computer-implemented "playlist assistance" function — while a media item is playing, the user invokes a UI feature that causes the system to research a plurality of media playlists and return a list of the playlists containing a selected item, artist, or genre. Representative independent claim 1 is notable for its negative limitations: results must be "exactly matched" to the search categories and returned as a "final output without any recommendations or suggestions" — a drafting choice that could cut both ways in an infringement case against algorithmic recommender-driven services. DynaMuse's complaints assert infringement of "one or more claims" without identifying specific claim numbers, and describe accused functionality generically (the iHeartMedia pleading is disclosed in the record as targeting a "playlist assistance" function that identifies playlists containing a selected media item). I could not verify, from the sources retrieved, which specific Sirius XM products or services DynaMuse names as the accused instrumentality in this complaint — the complaint's Exhibit 1 (Dkt. 1-1) may be a claim chart, but its contents were not retrievable. Based on the campaign's consistent target set, the accused features are likely SiriusXM's streaming-app playlist/station search or Pandora's playlist-discovery functions, but that is inference, not a sourced fact.

Procedural posture, venue, and why it matters. The case is at the earliest possible stage: complaint filed and summons issued (March 12, 2026), no answer, no scheduling order, and no substantive rulings in the retrieved docket. Venue in N.D. Tex. matters for three reasons. First, it is a departure from DynaMuse's initial E.D. Tex./Judge Gilstrap strategy in the 2025 wave — the shift to N.D. Tex. and D. Del. (and W.D. Tex. for iHeartMedia) suggests forum-shopping calibrated to each defendant's principal place of business or a search for dockets perceived as defense-friendly, though I did not find a publicly stated rationale. Second, this is a § 271 case with Judge Ada Brown presiding; I have not confirmed any prior patent-track record for her in a reliable source, so any prediction about her case-management posture would be speculation. Third, N.D. Tex.'s Dallas Division has drawn increased patent filings since TC Heartland, and the Northern District generally disposes of patent cases faster than the Eastern District's Marshall Division — relevant if DynaMuse's business model, as the SoundCloud dismissal suggests, is serial early settlement rather than trial.

Why the case is notable. It is one of a cluster of near-identical complaints asserting a single 2019-issued playlist-search patent against essentially the entire digital music/radio industry, which makes it a useful bellwether for how much traction '646 has: the SoundCloud dismissal with prejudice implies settlement, while the Sirius XM and iHeartMedia actions test the patent against much deeper-pocketed, litigation-seasoned defendants. The patent's "exact match / no recommendations" claim language also positions it awkwardly against modern recommendation engines, raising real § 101 and non-infringement questions if any defendant chooses to fight. Finally, the case bears watching for IPR linkage: I found no inter partes review, PGR, or IPR certificate challenging '646 in the sources searched, and the iHeartMedia complaint (as analyzed in third-party summaries) apparently makes no reference to prior litigation, IPRs, or licensing history — but I cannot rule out a recently filed petition that has not yet appeared in public dockets. This should be verified directly against the PTAB's Patent Trial and Appeal Board Endpoint and the '646 patent's USPTO transaction history before relying on it.

Sourcing caveats: Filing date, judge assignment, counsel, docket entries, patent number/issue date, and the DynaMuse campaign are grounded in Justia's docket, PacerMonitor/CourtListener records, and the NPE database. The patent's title, priority date, expiration estimate, and claim-1 sketch come from third-party complaint analysis rather than the patent text itself; the accused Sirius XM products, any damages theory, and the absence of IPR activity are not confirmed.

I'll research this case. Let me start with several searches.

Analytical Note on Scope and Sourcing

Before the chronology: this case is roughly six months old as of today (2026-09-13), and it is a low-volume NPE campaign filed by a single-lawyer-firm plaintiff. The only docket-level source I could fully retrieve was the Justia/PACER-Monitor snapshot, which was last retrieved 2026-03-12 — the filing date itself. There is no publicly indexed record I could reach of an answer, counterclaim, motion, scheduling order, Markman proceeding, or PTAB filing in this specific case. Everything downstream of the complaint below is therefore flagged as unverified, and the strategic picture has to be reconstructed largely from the plaintiff's parallel campaign on the same patent, which is well documented.

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1. Posture Snapshot

Docket source: https://dockets.justia.com/docket/texas/txndce/3:2026cv00803/[416637](/patent/416637)

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2. Chronology

A. Underlying patent and pre-suit history

• 2012-02-29 — Earliest priority date for the '646 patent (per the complaint analysis of the parallel iHeartMedia action).
• 2015-11-05 — Application filing date.
• 2019-11-26 — U.S. Patent No. 10,491,646 issues: "Mechanism for facilitating user-controlled features relating to media content in multiple online media communities and networks." The patent covers a "playlist assistance" function — a user selects a media item and the system returns a list of which of the user's playlists contain that item, asserted to be a "final output without any recommendations or suggestions."
• Unverified — The date DynaMuse LLC acquired the '646 patent. Stanford's NPE Litigation Database classifies DynaMuse under "Acquired patents" asserter categories, confirming it is a non-practicing acquirer rather than the original inventor. No assignment-record date was retrieved.
  • https://npe.law.stanford.edu/patent/10491646

B. Filing and initial pleadings (N.D. Tex.)

• 2026-03-12 — Docket #1: Complaint with jury demand. Filed by Rabicoff for DynaMuse LLC; filing fee $405, receipt ATXNDC-16269598. Attachments: Exhibit 1, Exhibit 2, Civil Cover Sheet. The complaint pleads infringement of "one or more claims" without identifying asserted claims with specificity (same pleading style as the parallel DynaMuse complaints).
• 2026-03-12 — Docket #2: Notice of Attorney Appearance (Rabicoff).
• 2026-03-12 — Docket #3: Rule 7.1 / Certificate of Interested Persons (clerk QC note: "No affiliate entered in ECF").
• 2026-03-12 — Docket #4–5: Request for summons; Notice of Report on Filing (AO 120).
• 2026-03-12 — Docket #6: New Case Notes; magistrate-judge consent notice (Magistrate Judge Toliver).
• 2026-03-12 — Docket #7: Form AO 120 emailed to the USPTO (notice_of_suit@uspto.gov).
• 2026-03-12 — Docket #8: Summons issued as to Sirius XM Radio Inc.
• 2026-03-12 — Case reassigned to Judge Ada Brown; Senior Judge Godbey no longer assigned per Special Order 3. This is a routine N.D. Tex. assignment mechanic, not a party-driven transfer.

C. Answer, counterclaims — NOT CONFIRMED

No answer or counterclaim appears in any docket snapshot I could retrieve. Given N.D. Tex. practice, Sirius XM would ordinarily answer or move by roughly mid-April 2026, frequently after an agreed extension. Two points matter strategically:

1. Sirius XM is a large, well-represented operating company. A § 1406(a) / TC Heartland venue challenge or a § 1404(a) transfer motion would be a predictable early move — but I found no record of one. Do not treat this as having occurred.
2. Similarly, invalidity counterclaims under §§ 101/102/103 would be expected against a "playlist assistance" software patent of this vintage, but I found no record.

If you have PACER access, the entries to pull first are the ones immediately following #8.

D. Pre-trial motions of substance — NONE ON RECORD

No motion to dismiss, no motion to transfer, no motion to stay pending IPR, and no summary judgment motion is reflected in the retrieved records. The case does not appear to have progressed past the pleadings/initial-case-management stage.

E. Claim construction (Markman) — NOT REACHED

No Markman briefing, no Markman order, no claim-construction hearing. Mediation/scheduling-order dates were likewise not retrieved.

F. Discovery — NO MILESTONES IDENTIFIED

No discovery orders, protective-order disputes, or ESI milestones appear in the accessible record.

G. Trial, verdict, post-trial motions — N/A

No trial setting, verdict, or JMOL/new-trial/fee motion exists. The case is roughly six months old.

H. Settlement, dismissal, judgment, appeal — N/A; CASE IS ACTIVE

No voluntary dismissal, stipulated judgment, or notice of appeal in this case. Status remains open per Justia and the Ex Parte AI Lab case page (https://ai-lab.exparte.com/case/dct/txnd/3:26-cv-00803/dynamuse-llc-v-sirius-xm-radio-inc).

I. Parallel PTAB proceedings — NONE FOUND

I found no IPR, PGR, or CBM petition directed at U.S. Pat. No. 10,491,646 by Sirius XM or any other party. Notably, the DynaMuse complaint in the parallel iHeartMedia action "does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history" (Ex Parte complaint analysis, 7:26-cv-00116). Absent a petition filed since the March 2026 complaint, there is no PTAB proceeding to report. The one-year § 315(b) bar clock for Sirius XM would run from service of the complaint in this case (late March/April 2026), putting any petition deadline in roughly March–April 2027 — worth calendaring.

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3. The Critical Context: Parallel DynaMuse Litigation on the Same Patent

Because the Sirius XM docket is bare, the most probative information about how this patent is litigated comes from DynaMuse's simultaneous campaign asserting the same '646 patent against streaming/audio platforms:

E.D. Tex. wave (filed 2025-11-06, all before Judge Rodney Gilstrap):

• DynaMuse LLC v. IDAGIO GmbH, 2:25-cv-01111
• DynaMuse LLC v. Mixcloud Ltd., 2:25-cv-01112
• DynaMuse LLC v. SoundCloud Global Ltd. & Co. KG, 2:25-cv-01113
• DynaMuse LLC v. Xandrie S.A., 2:25-cv-01114
• 2025-12-15/16 — Consolidation order; 2:25-cv-01113 designated lead case for all pretrial issues; scheduling conference set for 2026-01-22.
• 2026-01-08/09 — DynaMuse files notice of voluntary dismissal in the SoundCloud case.
• 2026-01-12/13 — Order dismissing the SoundCloud case with prejudice (Judge Gilstrap).
• https://www.courtlistener.com/docket/71884716/dynamuse-llc-v-soundcloud-global-limited-co-kg/

The with-prejudice dismissal three weeks after the consolidation order, in the lead case, is the campaign's most significant data point: it strongly suggests a settlement/license rather than a merits loss. That is the template DynaMuse is likely running — file broadly, consolidate, extract licenses, dismiss with prejudice.

2026 wave (post-Sirius XM):

• 2026-03-31 — DynaMuse LLC v. iHeartMedia, Inc., 7:26-cv-00116 (W.D. Tex., Midland Division, Rabicoff for plaintiff). Case referred to magistrate judge 2026-04-02; summons returned executed 2026-04-20. Same '646 patent.
• 2026-09-04 — DynaMuse LLC v. Audiomack Inc., 1:26-cv-01125 (D. Del.), pending judge assignment. Same '646 patent — asserting it in a fourth district.
• https://gaeflexstaging-dot-docketupdate.appspot.com/cases/Texas_Western_District_Court/7--26-cv-00116/DynaMuse_LLC_v._iHeartMedia_Inc/

The Sirius XM suit (2026-03-12) sits squarely in the middle of this expansion, filed the same day as a cluster of unrelated N.D. Tex. patent complaints (e.g., Secure Matrix LLC cases) — consistent with a high-volume, low-cost filing operation.

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4. Assessment of Likely Outcomes and Next Moves

What is confirmed: a 2026-03-12 complaint on the '646 patent against Sirius XM in N.D. Tex. before Judge Ada Brown; no answer, motion, Markman ruling, trial, or PTAB proceeding on public record.

What is likely but unverified:

• A § 1404(a) transfer motion to E.D. Tex. (to join the consolidated DynaMuse pretrial proceeding) or a venue/§ 101 motion from Sirius XM's counsel in the spring/summer of 2026. This is the single most consequential event to check for.
• A stay pending IPR motion only if a petition is filed; none exists yet.
• A quick, with-prejudice dismissal consistent with the SoundCloud resolution, likely preceded by a license.

Recommended verification steps (all require live PACER for 3:26-cv-00803):

1. Pull entries after #8 (2026-03-12) through the present for an answer, Rule 12 motion, or transfer motion.
2. Check the USPTO PTAB docket for any petition naming Sirius XM as petitioner and the '646 patent.
3. Check the N.D. Tex. docket for a scheduling order setting Markman/mediation deadlines.
4. Confirm whether the '646 patent's asserted claims were ever narrowed by DynaMuse in the E.D. Tex. consolidated case (any infringement contentions served there would be reusable here).

Caveat: I was unable to complete additional targeted searches on this case's post-filing docket and on PTAB activity (search budget exhausted); the "no record found" statements above mean not found in the sources I reached, not proven absent. Treat the post-March-2026 docket as an open question and confirm on PACER before relying on it.

I'll research this case to identify plaintiff's counsel of record.

Found the key docket entries. Let me dig into the attorneys listed.

Let me verify the full counsel list and confirm whether local counsel has appeared.

Counsel of Record for Plaintiff DynaMuse LLC

Case: DynaMuse LLC v. Sirius XM Radio Inc., No. 3:26-cv-00803 (N.D. Tex.), filed March 12, 2026, assigned to Judge Ada Brown.
Source: Justia docket; PACER Monitor

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1. Isaac Philip Rabicoff — Lead Counsel (confirmed on the docket)

Docket grounding (all N.D. Tex. 3:26-cv-00803):

• Dkt. 1 — COMPLAINT WITH JURY DEMAND against Sirius XM Radio Inc., filed by DynaMuse LLC (filed/signed by Rabicoff, March 12, 2026).
• Dkt. 2 — NOTICE of Attorney Appearance by Isaac Philip Rabicoff on behalf of DynaMuse LLC (March 12, 2026).
• Dkt. 3 — Certificate of Interested Persons/Disclosure Statement (DynaMuse LLC; clerk note "No affiliate entered in ECF").
• Dkt. 4–5 — Request for Clerk to Issue Summons; AO 120 patent-report notice, both filed by Rabicoff.
• Dkt. 8 — Summons issued as to Sirius XM Radio Inc.

Relevant patent-litigation experience: Rabicoff founded Rabicoff Law, which he states was among Lex Machina's top 3 most active patent-litigation firms in 2017. He runs a high-volume patent-assertion practice and is the recurring counsel in the DynaMuse campaign (see below), as well as in Cedar Lane Technologies, Patent Armory, and other NPE dockets. Firm bio states he has led licensing campaigns against Amazon, Microsoft, Sony, Apple, LG, Huawei, Samsung, and Google, argued before the Federal Circuit, and defeated institution of numerous IPRs/CBMs. (rabilaw.com/rabicoff)

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2. James O. Crewse — Local Counsel (listed on the docket record; appearance entry not independently confirmed)

Grounding and caveat: The Justia docket page for this case lists "Represented By: James O Crewse" in its attorney section. However, no separate "Notice of Attorney Appearance" by Mr. Crewse appears in the docket text retrieved (the retrieved docket runs only through the March 12, 2026 filing date). I could not confirm the Crewse appearance entry itself, nor a pro hac vice motion for Rabicoff, because the publicly retrieved docket is a snapshot limited to the filing date. Treat his role as reported but not docket-verified. That said, the pattern is consistent with Crewse's practice: he expressly markets himself as local counsel in N.D. Tex. federal cases, and his published sample of appearances includes a "Notice of Appearance of Local Counsel for Plaintiff" in N.D. Tex. (Ferrari v. Francis, 3:23-cv-00455, Dkt. 55). He also appears as local counsel in other N.D. Tex. patent dockets (Patent Armory Inc. v. JetSuiteX, 3:26-cv-01066; Navog LLC v. Omnitracs, 4:26-cv-00254). (CourtListener appearance; Martindale profile)

Relevant experience: AV Preeminent–rated Dallas business/commercial litigator (ex-Bell Nunnally & Martin; ex-partner, Riney Packard) whose practice includes IP and trade-secret litigation and who regularly serves as N.D. Tex. local counsel for out-of-state firms; former briefing attorney, Fourteenth Court of Appeals (Houston).

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What is not in the record

• No in-house counsel for DynaMuse appears on the retrieved docket.
• No additional Rabicoff Law attorneys (e.g., Kenneth A. Matuszewski, who is often listed as backup counsel in Rabicoff's PTAB filings) appear on this docket as of the retrieved snapshot.
• Defendant's counsel has not appeared in the retrieved records; Sirius XM's litigation team is therefore not yet identifiable. If the Crewse entry turns out to belong to the defendant's local-counsel entry rather than the plaintiff's, that would change the picture — I flag this as an open verification item rather than asserting it.
• Filings are not sealed on the face of the docket; the limitation is simply that the public docket snapshot stops at the filing date, so later appearances/pro hac vice applications may exist.

Useful context on the plaintiff's campaign

DynaMuse LLC is characterized in Stanford's NPE Litigation Database as an acquirer/asserter of patents (asserter category: "Acquired patents"). U.S. Patent No. 10,491,646 is the sole patent pleaded here, and it has been asserted in the same campaign against other audio/streaming defendants — DynaMuse v. SoundCloud Global, 2:25-cv-01113, DynaMuse v. Mixcloud, 2:25-cv-01112, and DynaMuse v. Xandrie, 2:25-cv-01114 (all E.D. Tex., filed Nov. 6, 2025; the SoundCloud case was voluntarily dismissed with prejudice in January 2026), and DynaMuse v. iHeartMedia, 7:26-cv-00116 (W.D. Tex., filed March 31, 2026) — all filed by Isaac Rabicoff. (Stanford NPE DB – DynaMuse; Stanford NPE DB – 10,491,646; CourtListener, SoundCloud docket)

Bottom line: Plaintiff's confirmed counsel of record is Isaac Philip Rabicoff of Rabicoff Law LLC (Harrison, NY), as lead counsel; a James O. Crewse of Crewse Law Firm, PLLC (Dallas, TX) is listed as plaintiff-side counsel on the docket aggregator and is best characterized as likely local counsel, pending confirmation of his appearance entry on PACER.

I'll research counsel appearances in this case. Let me start with several parallel searches.

Interesting — one docket snippet shows a "Represented By: James O Crewse." Let me dig into that and other counsel sources.

Defendant's counsel of record — what the record actually shows

Bottom line: I could not confirm a counsel appearance for Sirius XM Radio Inc. from the sources I was able to retrieve. The free docket mirror that is the backbone of the earlier sections (Justia, docket no. 416637) shows the case through Dkt. 8 (March 12, 2026) and lists no attorney appearing on behalf of Sirius XM. Its capture note reads "This docket was last retrieved on March 12, 2026" — i.e., the mirror is frozen at the filing date. Given that today is September 13, 2026, roughly six months after service, an answer and at least a defense-side appearance almost certainly exist on PACER; they are simply not visible in the free sources I could reach. I am flagging this as a sourcing gap rather than asserting Sirius XM is unrepresented.

Two things are in the retrieved record, and one of them is ambiguous:

1. Plaintiff's counsel (confirmed)

• Isaac Philip Rabicoff — lead counsel for DynaMuse LLC. Rabicoff Law LLC (Chicago, IL). Entered appearance via Dkt. 2 (March 12, 2026); he also filed the complaint (Dkt. 1), the AO 120 notice (Dkt. 5), and the Rule 7.1 disclosure (Dkt. 3). He is the common counsel across the entire DynaMuse campaign (Deezer, SoundCloud, Xandrie, iHeartMedia, Songtradr). Solo/small-firm NPE plaintiffs' counsel who litigates his own cases pro hac vice in multiple districts.

2. An unexplained second name on the docket — party affiliation not confirmed

• James Owen Crewse — Crewse Law Firm, PLLC, 5546/5919 Vanderbilt Ave., Dallas, TX 75206; Texas Bar No. 24045722; jcrewse@crewselawfirm.com; (214) 394‑2856. He appears in one Justia snippet for this case number alongside Rabicoff under a "Represented By:" label, but the snippet does not tell me which party he represents. I want to be explicit about that: I am not asserting he is Sirius XM's counsel.

  What is verifiable about him: he is a Dallas business/commercial litigator (South Texas College of Law, J.D. 2004; ex-briefing attorney, Fourteenth Court of Appeals) who markets himself as local counsel — a client review specifically praises him as "excellent local counsel for Texas" in an N.D. Tex. Communications Act/Copyright Act case. Confirmed N.D. Tex. patent docket presence includes Lab Technology LLC v. Solera Holdings, LLC, No. 4:26-cv-00297 (N.D. Tex.), and he appeared as local counsel for the plaintiff in Ferrari v. Francis, No. 3:23-cv-00455 (N.D. Tex.) (Dkt. 55, Feb. 6, 2024). His Martindale listing includes intellectual property litigation.

  Because Rabicoff is an out-of-state filer and Crewse's practice is built on local-counsel engagements, the more natural inference is that Crewse is local counsel for the plaintiff, DynaMuse — not for Sirius XM. But this is inference, not a sourced fact, and it could be reversed if Sirius XM retained a Dallas local firm. I would not rely on it without pulling the docket.

Note the internal inconsistency: Justia simultaneously reports the docket as "last retrieved March 12, 2026" and surfaces a Crewse "Represented By" entry. That means the page has been refreshed at some point after the filing date, or the retrieval stamp is stale. Either way, the mirror cannot be treated as a complete, current docket.

3. What I could not verify (do not treat as findings)

• No name, firm, or office location for Sirius XM's lead counsel, local counsel, or in-house counsel. My searches for Sirius XM's outside patent counsel returned no usable results, and I will not supply a firm by reputation — naming, e.g., a firm that commonly defends Sirius XM in other matters would be exactly the kind of fabrication the assignment prohibits.
• No answer, Rule 12(b) motion, corporate disclosure statement, unopposed extension, or pro hac vice motion by Sirius XM appears in the retrieved material. Any of these would carry the defense-side signature block.
• No lead/local counsel split, no in-house appearance. Sirius XM (which litigates heavily through Pandora and its streaming business) would ordinarily staff this with a national IP firm plus N.D. Tex. local counsel, but that is a general practice observation, not evidence about this case.

Where to look to close the gap

1. PACER docket for 3:26-cv-00803 (N.D. Tex., Dallas Division) — filings numbered 9 and above will include the answer/dispositive motion and the corresponding appearance notices. The N.D. Tex. local rules also require a local counsel designation, so expect at least two names for the defense.
2. N.D. Tex. CM/ECF attorney query and the clerk's office (Dallas) for admitted counsel on the case.
3. PTAB / USPTO — if Sirius XM filed an IPR against '646, the petition's mandatory notices list lead and back-up counsel and would corroborate the litigation team (the earlier section already recommended verifying '646's IPR status, which remains unverified).
4. Firm press releases / Law360 and Reuters Legal — a defense-side retention or an early motion (e.g., § 101) would typically generate a firm announcement.

Sourcing note: Everything above about Rabicoff and Crewse is grounded in Justia's docket for this case, CourtListener's RECAP filing (Crewse's local-counsel notice in Ferrari), Martindale, Avvo, Super Lawyers, and PacerMonitor's Lab Technology entry. The identification of Sirius XM's counsel is unconfirmed, and the Crewse party affiliation should be treated as an open question until the PACER docket is pulled.