Random Chat LLC v. Camelot Si LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Random Chat, LLC (Texas)
  • Defendant: CAMELOT SI, LLC (aka SHARPERIMAGE.COM) (Michigan)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 2:25-cv-11583, E.D. Mich., 05/30/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant’s residence in Michigan, its regular and established place of business within the district, and the commission of infringing acts in the district.
• Core Dispute: Plaintiff alleges that Defendant’s website and associated systems, which facilitate multimedia communication, infringe a patent related to methods for managing user-defined communications in online networks.
• Technical Context: The patent describes a framework for online communication platforms where users create profiles that define the rules and parameters for their interactions, a technology relevant to social networks and user-centric web applications.
• Key Procedural History: Plaintiff identifies as a non-practicing entity and discloses having entered into prior settlement licenses with other entities. The complaint argues these licenses do not trigger marking requirements under 35 U.S.C. § 287(a), asserting that infringement was not admitted and no patented articles were produced under those licenses.

Case Timeline

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

U.S. Patent No. 8,402,099 - "Method For Carrying Out A Multimedia Communication Based On A Network Protocol, Particularly TCP/IP And/Or UDP"

• Patent Identification: U.S. Patent No. 8,402,099, "Method For Carrying Out A Multimedia Communication Based On A Network Protocol, Particularly TCP/IP And/Or UDP," issued March 19, 2013.

The Invention Explained

• Problem Addressed: The patent asserts that prior video and chat systems were too "constrictive" and ill-suited for the complex, user-driven interactions required by emerging "social networks" and online "communities" ('099 Patent, col. 1:42-52; col. 2:4-11).
• The Patented Solution: The invention proposes a process where a user generates a "personalized user account in the form of a virtual subscriber profile" ('099 Patent, col. 2:22-24). This profile is not merely a static data record; the act of setting it up "establishes" the multimedia communication at the user's terminal by allowing the user to "freely define" parameters such as the mode of subscriber selection, the type of communication, and the number of communication links ('099 Patent, col. 2:25-31). The system architecture is described using a "pool principle" where users can be grouped into various sub-pools for different interaction types ('099 Patent, Fig. 2).
• Technical Importance: This user-centric approach provided a more flexible framework for online interactions, shifting control over communication rules from a centralized platform to the individual user's profile ('099 Patent, col. 2:50-60).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-20 ('099 Patent, col. 22:27-col. 25:50; Compl. ¶8).
• Independent Claim 1 requires:
  • A method for executing multimedia communication between terminals on a network.
  • A subscriber generating a "personalized user account in the form of a virtual subscriber profile" on a server or peer-to-peer network.
  • By setting up this profile, the communication is established at the terminals, where the profile is used to freely define a "mode of a subscriber selection," communication type, or number of links.
  • The subscriber selection mode must include a "random process" for linking to another random subscriber.
  • The subscriber selection mode must also include an "activatable call procedure" for linking to a subscriber from a "selection list," where users are organized into "sub-pools."

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendant’s "systems, products, and services that facilitate multimedia communication, in particular video, audio, and/or text chat between terminals," with specific reference to the website <www.sharperimage.com> (Compl. ¶8).

Functionality and Market Context

• The complaint alleges that Defendant operates systems for multimedia communication and, through its website and product instruction manuals, instructs customers on how to use these services in an infringing manner (Compl. ¶¶ 8, 11). The complaint does not provide specific details about the technical operation of any chat or communication features on the accused website.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in an unattached Exhibit B; the following analysis is based on the narrative allegations in the complaint body (Compl. ¶9).

’099 Patent Infringement Allegations

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Technical Questions: A primary question is what specific functionality on the <www.sharperimage.com> e-commerce website is alleged to meet the patent’s requirements for a user-configurable multimedia communication system. The complaint's allegations are general and do not map to specific features.
  • Scope Questions: The infringement analysis raises the question of whether a standard user account on an e-commerce site can be considered a "virtual subscriber profile" that "freely defines" communication parameters as required by the claim.
  • Evidentiary Questions: The complaint does not plead specific facts to support the presence of the "random process" or "selection list" limitations of claim 1. This raises the question of what evidence, if any, supports the allegation that the accused services practice these required claim elements.

V. Key Claim Terms for Construction

• The Term: "virtual subscriber profile"

• Context and Importance: This term is the central concept of the invention. The infringement case hinges on whether the accused system’s user data structure constitutes a "profile" that performs the active, defining functions required by the claims.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the underlying "account" as including "login data, contacts (friends), the subscriber profile, data relevant for switching and management, and other entries," which could be argued to cover a wide range of user account systems ('099 Patent, col. 19:10-14).
  • Evidence for a Narrower Interpretation: Claim 1 requires that "by setting up the virtual subscriber profile, the multimedia communication is established" and that "via the subscriber profile" selection modes "are freely defined." This language suggests the profile is not merely a data store but an active tool for configuring communication, potentially limiting its scope to more dynamic systems than a typical user account ('099 Patent, col. 22:36-45).

• The Term: "random process"

• Context and Importance: This is a required limitation of claim 1. Its construction will be critical, as the complaint pleads no specific facts alleging such a feature.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term itself could be argued to encompass any non-deterministic method of connecting users.
  • Evidence for a Narrower Interpretation: The specification describes this feature as enabling an "'accidental meeting' of two subscribers" that "involves a certain surprise effect similar to that encountered in everyday life," suggesting a specific type of user experience rather than any system-level randomization ('099 Patent, col. 2:66-col. 3:4).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement and contributory infringement based on Defendant's alleged instructions to customers through its website and product manuals (Compl. ¶¶ 10-11). Knowledge is alleged "from at least the filing date of the lawsuit," which may present a challenge for proving intent for pre-suit damages (Compl. ¶10).
• Willful Infringement: The prayer for relief seeks a finding of willfulness and treble damages, contingent on discovery revealing that Defendant had pre-suit knowledge of the patent and its infringement (Prayer for Relief ¶e).

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

• A core issue will be one of evidentiary sufficiency: can the generalized allegations against an e-commerce website satisfy the specific, functional limitations of Claim 1? The absence of factual allegations supporting key elements, such as the "random process" and the "selection list" call procedure, raises a foundational question about the factual basis for the infringement claim.
• The case will also turn on a question of definitional scope: can the term "virtual subscriber profile" be construed to cover a standard user account on a commercial website, or does the claim language requiring the profile to "establish" and "freely define" communication parameters demand a more dynamic and user-configurable system architecture that may not be present in the accused services?