Random Chat LLC v. Amazon.com Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Random Chat, LLC (Texas)
  • Defendant: Amazon.com, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00011, W.D. Tex., 01/14/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established place of business in the district, conducts substantial business there, and has committed alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s systems for multimedia communication infringe a patent related to methods for managing user interactions in online chat networks.
• Technical Context: The technology concerns systems for initiating and managing video, audio, and text communications in a way that models the complex interactions of "social networks."
• Key Procedural History: Plaintiff, a non-practicing entity, notes that it and its predecessors have entered into settlement licenses with other entities for its patents. It contends these licenses do not trigger marking requirements under 35 U.S.C. § 287(a) because they were entered into to terminate litigation and did not grant rights to produce a patented article.

Case Timeline

Date	Event
2007-08-28	Earliest Priority Date for U.S. Patent No. 8,402,099
2013-03-19	U.S. Patent No. 8,402,099 Issued
2025-01-14	Complaint Filed

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 failed to adequately support the complex user interactions required by emerging "social networks" and "communities," where users need more flexible ways to represent themselves, find each other, and form sub-groups (’099 Patent, col. 1:44-51, col. 2:5-11).
• The Patented Solution: The invention proposes a process where each user generates a "virtual subscriber profile" on a server or peer-to-peer network. This profile is more than just a login; it is a user-defined set of rules and preferences that dictates how that user’s communications are established. For example, the profile can define the mode for selecting other users (e.g., via random connection, a targeted search, or a pre-set list of "friends"), the type of communication (e.g., one-to-one, one-to-many), and the number of connections (’099 Patent, Abstract; col. 2:22-34).
• Technical Importance: The technology aimed to combine basic real-time communication functions with the richer, more flexible, and user-driven identity and connection management features of social networking platforms (’099 Patent, col. 1:52-68).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-20 (Compl. ¶8). Independent claim 1 is representative and recites the following essential 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.
  • Setting up this profile establishes the multimedia communication at the terminals by freely defining at least one of: a mode of subscriber selection, a communication type, a number of communication links, or a type of data transmission.
  • The subscriber selection mode includes a "random process for setting up a communication link" between a first subscriber and a random other subscriber.
  • The subscriber selection mode also includes an "activatable call procedure" for connecting with a subscriber from a "selection list," where these subscribers form "sub-pools" as subsets of a larger "subscriber pool."
• The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶8).

III. The Accused Instrumentality

Product Identification

• The complaint broadly accuses Defendant’s "systems, products, and services that facilitate multimedia communication, in particular video, audio, and/or text chat between terminals" (Compl. ¶8).

Functionality and Market Context

• The complaint does not describe the specific functionality of any particular Amazon product. Instead, it alleges that Defendant "maintains, operates, and administers" infringing systems generally (Compl. ¶8). As an example of infringing activity, the complaint points to a URL for what appears to be a customer service portal, stating that Defendant "offers the products and/or service with instruction or advertisement that suggests an infringing use" (Compl. ¶11). No further details on the technical operation or market context of any specific accused product are provided.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "Exhibit B" to support its infringement allegations; however, this exhibit was not filed with the complaint (Compl. ¶9). The narrative allegations in the complaint are general and do not map specific features of an accused product to the limitations of the asserted claims. The complaint's infringement theory is that Defendant's systems for multimedia communication perform the functions claimed in the ’099 Patent because they "facilitate multimedia communication, in particular video, audio, and/or text chat between terminals" (Compl. ¶8).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Pleading Sufficiency: A foundational issue for the court may be whether the complaint's allegations, which lack specific facts mapping accused product features to claim limitations, meet the plausibility standard for patent infringement pleading established by federal court precedent.
  • Technical Scope: A central question will be whether the architecture of Amazon's modern, large-scale communication services can be shown to operate according to the specific "virtual subscriber profile" and "sub-pool" structure described in the patent, or if they employ a fundamentally different technical approach for managing user connections.

V. Key Claim Terms for Construction

• The Term: "virtual subscriber profile"

  • Context and Importance: This term appears in independent claim 1 and is the core architectural element of the invention. The definition of this term is critical, as it will determine what set of user data and settings constitutes the infringing "profile." Practitioners may focus on whether this term is limited to a single, consolidated user-managed entity, as described in the patent, or if it can be read more broadly on distributed data across a cloud service.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states the profile is a "personalized user account" that can be on a "server or in a peer-to-peer network," which could suggest it is not tied to a single, monolithic structure (’099 Patent, col. 2:23-25).
    • Evidence for a Narrower Interpretation: The specification describes the profile as a "collection place for tags" that the subscriber "substantially manages himself" and which contains specific data categories like "WhoAmI tags," "like tags," and "dislike tags" (’099 Patent, col. 11:30-47, Fig. 5c). This could support a narrower construction requiring a specific, user-centric data structure.

• The Term: "random process"

  • Context and Importance: Claim 1 requires the subscriber selection mode to include a "random process." The interpretation of "random" will be key to infringement, as many systems that appear random to a user are algorithmically determined. The dispute will likely center on whether a pseudo-random or preference-filtered connection process meets this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes a "random connection with preferences," where a user is connected to a partner from a "preferred group," suggesting that "random" does not mean mathematically pure randomness but can be constrained by user criteria (’099 Patent, col. 9:13-17).
    • Evidence for a Narrower Interpretation: The patent also describes a "random connection without preferences" where the "subscriber is connected to a random partner from the main pool," which could imply a less constrained, more truly arbitrary selection is also contemplated (’099 Patent, col. 9:7-9).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant instructs customers on how to use its services to cause infringement (Compl. ¶10). It alleges contributory infringement by claiming the accused services are not staple articles of commerce and their "only reasonable use is an infringing use" (Compl. ¶11). The factual basis cited for these allegations is a single URL to a customer service webpage (Compl. ¶11).
• Willful Infringement: The complaint alleges knowledge of the ’099 patent "from at least the filing date of the lawsuit," which supports a claim for post-filing willfulness (Compl. ¶10, ¶11). The prayer for relief also seeks a finding of willful infringement and treble damages should discovery reveal pre-suit knowledge (Compl. ¶VI(e)).

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

1. Evidentiary Sufficiency: A threshold issue will be one of pleading adequacy: do the complaint's high-level allegations, which identify no specific accused product and provide no factual mapping of technology to claim limitations, state a plausible claim for patent infringement, or will they be found deficient?
2. Definitional Scope: The case will likely turn on a question of claim construction: can the term "virtual subscriber profile," which the patent describes as a specific, user-managed collection of data and preferences, be construed to read on the complex, distributed account management systems used in modern cloud-based communication services?
3. Technical Operation: A key factual question will be one of functional implementation: does any accused Amazon service actually employ the specific "random process" for connection and the "subscriber sub-pool" architecture for user grouping as required by Claim 1, or is there a fundamental mismatch in technical operation?