Random Chat LLC v. Te Connectivity Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Random Chat, LLC (Texas)
  • Defendant: TE Connectivity Corporation (Pennsylvania)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.
• Case Identification: 2:25-cv-06156, E.D. Pa., 10/29/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Pennsylvania because Defendant maintains a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s systems, products, and services for multimedia communication infringe a patent related to methods for managing video, audio, and text chat between user terminals on a network.
• Technical Context: The technology at issue concerns the architecture of online communication platforms, particularly those enabling social networking features and flexible user interaction modes like random matching and pre-defined contact lists.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and that it and its predecessors have entered into settlement licenses with other entities, which it argues obviates patent marking requirements.

Case Timeline

Date	Event
2007-08-28	’099 Patent Priority Date
2013-03-19	’099 Patent Issue Date
2025-10-29	Complaint Filing Date

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 restrictive for the complex and differentiated communication requirements of modern online "social networks" and "communities" (’099 Patent, col. 1:43-52). It notes that the clear separation between a website provider and a user was becoming blurred, with users needing more flexible tools to represent themselves and manage their interactions (’099 Patent, col. 1:63-2:2).
• The Patented Solution: The invention describes a process where a user generates a "virtual subscriber profile" on a server or peer-to-peer network (’099 Patent, col. 2:22-26). This profile acts as a central control hub, allowing the user to "freely define" key aspects of their communication, such as the method for selecting other users (e.g., random matching, searching, or calling from a friends list), the type of communication (e.g., one-to-one, one-to-many), and the number of connections (’099 Patent, col. 2:26-30). This architecture, depicted in the hierarchical layer model of Figure 1, is designed to support more dynamic and user-driven social interactions than conventional chat systems (’099 Patent, Fig. 1).
• Technical Importance: The claimed method provides a framework for user-centric control over online multimedia interactions, reflecting the shift from static communication tools to dynamic social platforms. (Compl. ¶8).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 (Compl. ¶9). Independent claim 1 is central to the dispute.
• Claim 1 Elements:
  • A method for executing a multimedia communication between terminals on a network.
  • At least one subscriber generates a personalized user account in the form of a "virtual subscriber profile" on a server or peer-to-peer network.
  • The multimedia communication is established at each terminal by setting up the virtual subscriber profile.
  • Via the subscriber profile, a "mode of a subscriber selection," a communication type, a number of communication links, or a type of data transmission are "freely defined."
  • The subscriber selection mode includes a "random process" for linking to a random subscriber.
  • The subscriber selection mode also includes an "activatable call procedure" for linking to a subscriber from a stored selection list, where these subscribers form a sub-pool.
• The complaint does not explicitly reserve the right to assert dependent claims, but the allegation covers claims 1-20 broadly (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The complaint accuses unspecified "systems, products, and services that facilitate multimedia communication, in particular video, audio, and/or text chat between terminals" (Compl. ¶9).

Functionality and Market Context

• The complaint does not describe the functionality of any specific accused product. It provides a URL ("https://www.te.com/en/products/connectors/intersection/underwater-switches.html") as an example of Defendant's products and services (Compl. ¶11, ¶12). This URL directs to a webpage for industrial "underwater switches," a product category that does not appear to relate to the multimedia communication technology described in the patent-in-suit. The complaint makes no allegations regarding the market positioning of any specific product. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "Exhibit B" to support its infringement allegations; however, this exhibit was not included with the filed complaint (Compl. ¶10). In the absence of a claim chart, the infringement theory is based on the general allegation that Defendant "maintains, operates, and administers systems, products, and services that facilitate multimedia communication" that practice the claimed methods (Compl. ¶9). The complaint does not provide specific factual allegations mapping elements of any accused product to the limitations of the asserted claims.

• Identified Points of Contention:
  • Evidentiary Questions: The central point of contention will be identifying the specific accused instrumentality. The complaint's failure to name a relevant product and its citation to a seemingly unrelated product webpage for "underwater switches" raises the question of whether Plaintiff has a good-faith basis for its infringement allegations against any specific TE Connectivity product or service (Compl. ¶11).
  • Scope Questions: Assuming a relevant product is identified, a likely dispute will concern whether its functionality meets the "freely defined" limitation of claim 1. The question will be whether the accused system provides users with the specific combination of selection modes (random process and activatable call procedure) and user-driven control over communication types as required by the claim (’099 Patent, col. 22:42-53).

V. Key Claim Terms for Construction

• The Term: "virtual subscriber profile"

  • Context and Importance: This term is the core architectural element of the invention. Its construction will determine whether a generic user account in a communication system is sufficient to infringe, or if a more specialized data structure with specific user-configurable parameters is required. Practitioners may focus on this term because its scope is critical to distinguishing the invention from prior art communication systems.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states the profile is a "personalized user account" that includes basic elements like "login data, contacts, ... switching and management-relevant data and other entries" (’099 Patent, col. 2:45-48). This could support a reading that covers a wide range of user account systems.
    • Evidence for a Narrower Interpretation: The specification describes the profile as a tool through which a subscriber can "represent himself and his person comprehensively inside the network" and which serves as a "collection place for tags" that define connection preferences (’099 Patent, col. 2:38-43; col. 11:31-33). This language, tied to the "freely defined" communication modes, may support a narrower construction limited to profiles that enable a high degree of user customization for social networking.

• The Term: "freely defined"

  • Context and Importance: This term modifies the user's ability to control communication parameters (selection mode, type, links) via the profile. The degree of freedom required will be a key issue. If "freely" requires a high level of user control over all listed parameters, it may be harder to prove infringement than if it simply means the user has some choice in setting up the communication.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself suggests a lack of restriction. The specification describes various options available to the user, such as switching between one-to-one and one-to-many communication types, which supports a flexible, user-driven interpretation (’099 Patent, col. 4:49-52).
    • Evidence for a Narrower Interpretation: Claim 1 itself constrains the "subscriber selection mode" by requiring it to include both a "random process" and an "activatable call procedure." An argument could be made that "freely defined" must be read in the context of these specific, enumerated functions, rather than implying limitless user choice.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendant encourages and instructs customers on how to use its products and services in an infringing manner through its "website and product instruction manuals" (Compl. ¶11-12). Contributory infringement is based on the allegation that the accused products' "only reasonable uses are infringing uses" and they are not staple articles of commerce (Compl. ¶12).
• Willful Infringement: The complaint does not allege pre-suit knowledge of the ’099 Patent. It alleges knowledge "from at least the filing date of the lawsuit" and reserves the right to amend if discovery reveals an earlier date of knowledge (Compl. ¶11).

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

1. Evidentiary Specificity: A threshold issue is whether the complaint's allegations satisfy federal pleading standards. The lack of any identified accused product related to multimedia communication, coupled with a citation to an industrial hardware webpage, raises a fundamental question of factual basis that will likely be an early focus of the litigation.

2. Definitional Scope: Should the case proceed, a core legal question will be the construction of "virtual subscriber profile." The dispute will likely center on whether the term can be broadly construed to read on generic user accounts in any online system or is limited to the highly configurable, socially-oriented profiles described in the patent's specification, which allow users to "freely define" specific and varied modes of interaction.