Random Chat LLC v. Samsung Electronics America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Random Chat, LLC (Texas)
  • Defendant: Samsung Electronics America, Inc. (New Jersey)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 2:25-cv-00625, E.D. Tex., 06/12/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has committed acts of infringement in the district and maintains a regular and established place of business there.
• Core Dispute: Plaintiff alleges that Defendant’s systems and services that facilitate multimedia communication, such as video, audio, and text chat, infringe a patent related to methods for establishing and managing such communications through user profiles.
• Technical Context: The technology relates to the architecture of online communication platforms, specifically how users create profiles that define the parameters for initiating and conducting real-time interactions within a network.
• Key Procedural History: Plaintiff states it is a non-practicing entity and that its predecessors-in-interest have entered into settlement licenses with other entities, though the terms are confidential. Plaintiff argues that because these were settlement licenses and no product was produced, or alternatively because it will limit its assertions to method claims, the patent marking requirements of 35 U.S.C. § 287(a) do not apply.

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" for the increasingly complex communication requirements of "social networks" and "communities." (’099 Patent, col. 2:6-11). It notes a need for systems that can better replicate real-world social interactions, where users represent themselves, find each other, and communicate in various flexible ways. (’099 Patent, col. 1:42-62).
• The Patented Solution: The invention proposes a process where a user generates a "personalized user account in the form of a virtual subscriber profile" on a server or peer-to-peer network. (’099 Patent, col. 2:22-24). By setting up this profile, the user can "freely define" key aspects of the communication, such as the method of selecting another user (e.g., random, search, or from a list), the type of communication (e.g., one-to-one, one-to-many), and the type of data transmission. (’099 Patent, col. 2:26-31). The system architecture is described as a hierarchical structure of layers, including a database layer, link layer, subscriber layer, and front-end layer, which work together to manage these profile-driven communications. (’099 Patent, Abstract; Fig. 1).
• Technical Importance: The described approach aims to shift control over communication parameters to the end-user via a detailed profile, allowing for more dynamic and varied interactions than static chat room models. (’099 Patent, col. 2:50-57).

Key Claims at a Glance

• The complaint asserts claims 1-20 of the ’099 Patent. (Compl. ¶9).
• Independent claim 1, a method claim, includes the following essential elements:
  • executing a multimedia communication between a totality of 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 in a peer-to-peer network;
  • by setting up the virtual subscriber profile, the multimedia communication is established at each of the terminals;
  • via the subscriber profile, a mode of subscriber selection, a communication type, a number of communication links, or the type of data transmission are freely defined;
  • the subscriber selection mode includes a random process for linking a first subscriber to a random subscriber; and
  • the subscriber selection mode includes an activatable call procedure for linking to a subscriber from a selection list, where subscribers form sub-pools within a larger subscriber pool.
• The complaint does not specify which dependent claims may be asserted.

III. The Accused Instrumentality

• Product Identification: The complaint broadly identifies "systems, products, and services that facilitate multimedia communication, in particular video, audio, and/or text chat between terminals" that are maintained, operated, and administered by Defendant Samsung Electronics America, Inc. (Compl. ¶9). No specific Samsung product (e.g., Samsung Messages) is named.
• Functionality and Market Context: The complaint alleges that the accused instrumentalities provide functionality for multimedia communication. (Compl. ¶9). It further alleges that Defendant provides instructions on its support website for using these features. (Compl. ¶¶11-12). The complaint does not contain specific details about the technical operation or architecture of the accused Samsung services.

IV. Analysis of Infringement Allegations

The complaint states that support for its infringement allegations may be found in a chart attached as Exhibit B. (Compl. ¶10). This exhibit was not provided with the complaint. The complaint’s narrative theory is that by maintaining and operating systems that facilitate multimedia chat, and by instructing customers on how to use them, Defendant infringes claims 1-20 of the ’099 patent. (Compl. ¶¶9, 11). Without the referenced claim chart, it is not possible to map specific accused functionalities to the elements of the asserted claims.

No probative visual evidence provided in complaint.

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 infringement analysis will depend on whether a "virtual subscriber profile" is construed broadly to mean any collection of user settings in a modern communication application or narrowly to require the specific structures and functions described in the patent. Practitioners may focus on this term because its scope will likely determine whether the claims read on a wide range of modern software or are limited to a more specific implementation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the profile as a "personalized user account" that includes "login data, contacts, the profile, switching and management-relevant data and other entries." (’099 Patent, col. 2:45-48). This language could support a construction covering general user account settings.
  • Evidence for a Narrower Interpretation: The specification ties the profile to a system with a specific "hierarchical layer structure" (database, link, subscriber, front-end layers). (’099 Patent, Abstract). The term could be construed to require this underlying architecture or the ability to define a comprehensive set of parameters, including "tag variables," "jingles," and "mashups." (’099 Patent, col. 5:20-25; col. 11:51-63).

• The Term: "freely defined"

• Context and Importance: This functional language modifies how the "subscriber selection mode" and "communication type" are established. The dispute may turn on the degree of freedom required. Does any user-selectable option meet this limitation, or must the user have the ability to define the parameters from a wider, more fundamental set of choices as suggested by the patent?

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself suggests a range of options ("a mode of a subscriber selection... a communication type or a number of communication links") that are "freely defined," which could be interpreted as simply being selectable by the user. (’099 Patent, col. 22:37-41).
  • Evidence for a Narrower Interpretation: The specification emphasizes that the invention's object is to "override the constrictions" of prior systems and allow for "flexible" social networking. (’099 Patent, col. 2:7-11). This purpose could support a narrower construction requiring a greater degree of user-driven customization than merely selecting from a few predefined modes.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant "actively encouraged or instructed others (e.g., its customers...)" through its website and product manuals on how to use its products in an infringing manner. (Compl. ¶11). It also pleads contributory infringement, alleging the accused services are not staple commercial products and that their only reasonable use is an infringing one. (Compl. ¶12).
• Willful Infringement: The complaint alleges that Defendant has known of the ’099 patent and its underlying technology "from at least the filing date of the lawsuit." (Compl. ¶11). This appears to be a basis for post-suit willfulness. The prayer for relief also seeks a finding of willfulness should discovery reveal pre-suit knowledge of the patent. (Compl. ¶(e)).

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

1. A central issue will be one of claim scope: Can the term "virtual subscriber profile," as used in the patent, be construed to cover the user account and settings architecture of a modern, general-purpose multimedia messaging service, or is its meaning limited by the more specific hierarchical system and extensive customization features described in the patent’s embodiments?
2. A key evidentiary question will be one of technical specificity: The complaint makes broad allegations without identifying a specific accused product or its precise functions. A primary hurdle for the plaintiff will be to produce evidence mapping the highly specific elements of the asserted claims (e.g., a "random process" for subscriber selection, the creation of "sub-pools") to the actual operation of an accused Samsung service.
3. The case may also present a significant question regarding patent validity: Given the 2007 priority date, the defense will likely question whether the asserted claims, particularly if construed broadly, are valid over the state of the art in online chat, social networking, and user-profile-based systems that existed at the time.