Random Chat LLC v. Altra Federal Credit Union

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Random Chat, LLC (Texas)
  • Defendant: Altra Federal Credit Union (Wisconsin)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 2:25-cv-00478, E.D. Tex., 05/05/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains regular and established places of business within the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s systems and services for online multimedia communication infringe a patent related to methods for managing user-profile-based interactions in a network environment.
• Technical Context: The technology at issue concerns the architecture for online communication platforms, particularly those allowing users to create detailed profiles that define how they connect and interact with other users.
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity and notes that it and its predecessors-in-interest have previously entered into settlement licenses. The complaint includes a detailed argument that the patent marking requirements of 35 U.S.C. § 287(a) do not apply, as no patented articles were produced under these 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’s background section describes prior art video and chat systems as being too "constrictive" to meet the "increasingly higher, differentiated and more complex communication requirements" of emerging "social networks" and online "communities" (’099 Patent, col. 2:4-11, col. 1:43-52).
• The Patented Solution: The invention proposes a method where each user ("subscriber") generates a "personalized user account in the form of a virtual subscriber profile" on a server or peer-to-peer network (’099 Patent, col. 2:23-26). By setting up this profile, the user can "freely define[]" key parameters of their communication, such as the mode of selecting other users (e.g., random, search-based), the communication type (e.g., one-to-one, one-to-many), and the number of communication links (’099 Patent, col. 2:27-31). This profile-centric architecture, illustrated in the hierarchical layer model of Figure 1, is designed to enable more flexible and user-driven interactions than previous systems (’099 Patent, Abstract; Fig. 1).
• Technical Importance: The described technical approach aimed to provide a more flexible framework for online interactions, mirroring the complex and user-defined ways people connect within real-world social networks (’099 Patent, col. 1:56-61).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-20 of the ’099 Patent (Compl. ¶10). Independent claim 1 is central to the asserted method.
• Essential elements of independent Claim 1 include:
  • A method for executing a multimedia communication between terminals on a network.
  • At least one subscriber generates a personalized user account as a "virtual subscriber profile" on a server or peer-to-peer network.
  • By setting up this profile, communication is established at the terminals.
  • The profile is used to "freely define[]" a "mode of a subscriber selection," a communication type, a number of links, or a data transmission type.
  • The subscriber selection mode includes a "random process" for connecting to another random user profile.
  • The subscriber selection mode also includes an "activatable call procedure" for connecting with a user from a pre-stored "selection list."

III. The Accused Instrumentality

Product Identification

• The complaint accuses Defendant’s "systems, products, and services that facilitate multimedia communication, in particular video, audio, and/or text chat between terminals," and provides Defendant's website, as an example (Compl. ¶10).

Functionality and Market Context

• The complaint alleges that Defendant "maintains, operates, and administers" the accused systems but does not describe the specific technical features or functionality of these services (Compl. ¶10). The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific operations or market positioning beyond its association with a federal credit union (Compl. ¶2).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "Exhibit B" but does not include it with the filing (Compl. ¶11). The narrative infringement theory is presented at a high level, alleging that Defendant's operation of systems facilitating multimedia chat infringes claims 1-20 of the ’099 Patent (Compl. ¶10). The complaint does not specify which features of Defendant's services allegedly practice the limitations of the asserted claims.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question may be whether a customer account on a financial institution's website can be considered a "virtual subscriber profile" in the manner contemplated by the patent, which describes profiles used to "freely define[]" complex communication modes within a social network context.
  • Technical Questions: The complaint does not identify any specific feature of the accused services that performs the "random process" for subscriber selection or the "activatable call procedure" for connecting to users on a "selection list" as required by Claim 1. The existence and operation of such features will be a primary technical question.

V. Key Claim Terms for Construction

• The Term: "virtual subscriber profile"

  • Context and Importance: This term is the central component of the claimed invention. The dispute may turn on whether a standard user account for a financial service constitutes a "virtual subscriber profile" or if the term requires the extensive, user-configurable attributes for self-portrayal and communication management described in the patent's specification.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim itself defines the term as "a personalized user account" (’099 Patent, col. 22:34-35), language that could be argued to encompass any individualized user login.
    • Evidence for a Narrower Interpretation: The specification describes the profile in detail as a platform for a subscriber's "self-portrayal," including uploading images, text, and special tags, which in turn are used to define preferences for connecting with other users in a community setting (’099 Patent, col. 2:38-44, col. 11:29-40).

• The Term: "freely defined"

  • Context and Importance: Claim 1 requires that the subscriber profile allows communication parameters to be "freely defined." The infringement analysis will depend on the degree of user control and customization required by this term. Practitioners may focus on whether the accused system provides the type of open-ended configuration envisioned by the patent or merely offers a limited set of pre-determined communication options.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself suggests a high degree of user autonomy without express limitation in the claim body (’099 Patent, col. 22:45).
    • Evidence for a Narrower Interpretation: The specification provides specific examples of what can be "defined," such as a "subscriber selection mode," a "communication type," and a "number of communication links," suggesting the scope is tied to these specific categories of communication management (’099 Patent, col. 2:27-31).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant instructs its customers on how to use the accused services through its website and manuals (Compl. ¶12). It alleges contributory infringement on the grounds that the services are not staple commercial products and their "only reasonable use is an infringing use" (Compl. ¶13).
• Willful Infringement: The complaint alleges knowledge of the ’099 Patent as of the filing date of the lawsuit and reserves the right to prove pre-suit knowledge through discovery (Compl. ¶12, ¶13).

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

• A core issue will be one of definitional scope: can the patent's central concept of a "virtual subscriber profile," which is described in the specification as a tool for self-portrayal and connection-building within a social network, be construed to cover a standard customer account on a financial institution's website?
• A key evidentiary question will be one of technical correspondence: what specific evidence will be presented to show that the accused credit union website implements the distinct "subscriber selection mode[s]" required by Claim 1, such as a "random process" for connecting users and a "call procedure" based on a "selection list"? The complaint does not currently provide a factual basis for these allegations.