Random Chat LLC v. LG Electronics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Random Chat, LLC (Texas)
  • Defendant: LG Electronics, Inc. (Republic of Korea) and LG Electronics U.S.A., Inc. (New Jersey)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 2:25-cv-00809, E.D. Tex., 08/18/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants have committed acts of infringement and have a regular and established place of business in the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s multimedia communication products and services infringe a patent related to methods for executing communications in a network environment based on personalized user profiles.
• Technical Context: The technology at issue falls within the domain of online social networking and real-time multimedia communication, which involves managing how users connect and interact via video, audio, and text chat.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and discloses that its predecessors-in-interest have entered into settlement licenses with other entities, which may raise issues related to damages and marking requirements.

Case Timeline

Date	Event
2007-08-28	’099 Patent Priority Date
2013-03-19	’099 Patent Issue Date
2025-08-18	Complaint Filing Date

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

• 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 (’099 Patent).
• The Invention Explained:
  • Problem Addressed: The patent’s background section describes prior art video and chat systems as being too "constrictive" to meet the complex and differentiated communication requirements of modern "social networks" and "communities" (’099 Patent, col. 2:4-11). It notes the need for more flexible technical means that can better replicate the nuances of real-world social interactions online (’099 Patent, col. 1:53-66).
  • The Patented Solution: The invention proposes a method centered on a "virtual subscriber profile," which is a personalized user account generated on a server or peer-to-peer network (’099 Patent, Abstract). By setting up this profile, a user can "freely define" critical aspects of their communication, such as the mode for selecting communication partners, the type of communication (e.g., one-to-one, one-to-many), and the number of connections. This profile-based system architecture is designed to give users granular control over their network interactions (’099 Patent, col. 2:22-31, col. 2:56-62).
  • Technical Importance: The claimed approach provides a flexible framework for managing complex, multi-party communications, moving beyond simple point-to-point chat to accommodate the dynamic user groupings and interaction styles characteristic of social networks (’099 Patent, col. 1:46-53).
• Key Claims at a Glance:
  • The complaint asserts independent claim 1 and dependent claims 2-20 (Compl. ¶10).
  • Independent Claim 1 of the ’099 Patent recites a method with the following essential elements:
    • 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.
    • By setting up the profile, the multimedia communication is established at each terminal.
    • Via the 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 with a random subscriber.
    • The subscriber selection mode also includes an "activatable call procedure" for linking with a subscriber from a "selection list," where those on the list form an open or closed "subscriber sub-pool."

III. The Accused Instrumentality

• Product Identification: The complaint accuses "systems, products, and services that facilitate multimedia communication, in particular video, audio, and/or text chat between terminals" operated by LG (Compl. ¶10). It specifically references online support documentation for the "LG ThinQ" app, formerly the "LG TV Plus Remote app" (Compl. ¶¶12-13).
• Functionality and Market Context: The complaint alleges the accused instrumentalities provide functionality for multimedia communication between terminals (Compl. ¶10). The complaint does not provide sufficient detail for analysis of the specific technical operation of the accused communication features within the LG ThinQ app or other LG services.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in an "Exhibit B" to support its infringement allegations, but this exhibit was not provided (Compl. ¶11). The complaint's narrative alleges that Defendants "maintain, operate, and administer systems, products, and services that facilitate multimedia communication" and that these systems infringe one or more claims of the ’099 patent (Compl. ¶10). Without the claim chart, a detailed element-by-element analysis is not possible based on the complaint alone.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent and the complaint’s general allegations, several points of contention may arise.
  • Scope Questions: A central question may be whether creating a user account within the accused LG ThinQ application—which may be primarily for device control—constitutes generating a "virtual subscriber profile" for the purpose of "freely defin[ing]" communication modes as required by the claims. The dispute could focus on whether the accused profile serves the specific communication-defining functions described in the patent (’099 Patent, col. 2:26-31).
  • Technical Questions: The infringement analysis will likely require evidence of whether the accused LG services actually implement the specific combination of features recited in claim 1. For example, a key question is what evidence the complaint provides that the accused systems offer both a "random process" for connection and an "activatable call procedure" from a "selection list," as both are required elements of the claimed "subscriber selection mode" (’099 Patent, Claim 1).

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 depends on whether a user account in LG's system meets this definition. Practitioners may focus on this term because its construction will determine if the accused LG user accounts, potentially created for broad device management, fall within the scope of a profile specifically intended to define communication parameters.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the underlying "account" as that which "describes the identity of a subscriber within the process" and includes "login data, contacts, the profile, switching and management-relevant data" (’099 Patent, col. 2:44-48).
    • Evidence for a Narrower Interpretation: The specification directly links the profile to defining communication rules, stating, "The subscriber profile thereby determines the subscriber selection mode, which precedes the communication, the type of the communication and the number of the communication links" (’099 Patent, col. 2:56-60). This suggests the term requires more than simple identity management.

• The Term: "subscriber selection mode"

  • Context and Importance: Claim 1 requires this "mode" to include two distinct functionalities: a "random process" and a "call procedure." The viability of the infringement claim rests on proving the accused systems contain a mode with this specific combination of features.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself could be argued to encompass any user interface mechanism for selecting a communication partner.
    • Evidence for a Narrower Interpretation: Claim 1 itself defines the term by what it must include ("a random process" and "an activatable call procedure"). The specification reinforces this by describing these as distinct options, such as a "random connection without preferences" versus directly contacting users from a "so-called friends panel" (’099 Patent, col. 9:6-11, col. 9:26-30).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendants encourage and instruct customers on how to use the accused products through websites and instruction manuals (Compl. ¶12). It also alleges contributory infringement, asserting the products are not staple articles of commerce and their only reasonable use is an infringing one (Compl. ¶13).
• Willful Infringement: Willfulness is alleged based on Defendants' knowledge of the ’099 patent "from at least the filing date of the lawsuit" (Compl. ¶¶12-13). The complaint reserves the right to amend this allegation if discovery reveals pre-suit knowledge (Compl. ¶12, n.1).

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

• A core issue will be one of definitional scope: can a user account within Defendant's device-management ecosystem be construed as the claimed "virtual subscriber profile," which the patent describes as a specific tool for actively defining and controlling how a user communicates and connects with others in a network?
• A key evidentiary question will be one of functional presence: can Plaintiff demonstrate that the accused LG services implement the specific combination of "subscriber selection mode" features required by Claim 1, including both a "random process" for connection and a "call procedure" from a predefined "selection list"?