Random Chat LLC v. Stanley Black & Decker Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Random Chat, LLC (Texas)
  • Defendant: Stanley Black & Decker, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00098, W.D. Tex., 02/28/2025
• 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, has committed alleged acts of infringement there, and conducts substantial business in the forum.
• Core Dispute: Plaintiff alleges that Defendant’s systems for facilitating multimedia communications infringe a patent related to methods for managing user-defined communication sessions in a network.
• Technical Context: The technology relates to the software architecture for online communication platforms, particularly those enabling complex social interactions beyond simple one-to-one messaging.
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity and states that it and its predecessors have entered into prior settlement licenses, but argues these licenses did not trigger marking requirements under 35 U.S.C. § 287 because they did not permit the production of a patented article.

Case Timeline

Date	Event
2007-08-28	’099 Patent Priority Date
2013-03-19	’099 Patent Issue Date
2025-02-28	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," issued March 19, 2013

The Invention Explained

• Problem Addressed: The patent asserts that prior art video and chat systems were too "constrictive" to support the increasingly complex interactions of online "social networks" and "communities." These prior systems did not adequately allow users to represent themselves, define how they connect with others, or form distinct sub-groups within a larger network (’099 Patent, col. 1:40-50).
• The Patented Solution: The invention is a process where a user establishes a "virtual subscriber profile" that acts as a central control hub for their communications (’099 Patent, col. 2:23-26). Instead of the system dictating connection rules, the user's profile defines key parameters, including the "mode of a subscriber selection" (e.g., random connection, searching, or selecting from a list), the communication type (e.g., one-to-one, one-to-many), and the number of communication links (’099 Patent, col. 2:27-34). This profile-centric architecture is designed to enable more flexible and user-driven online interactions, such as "accidental meetings" or participation in different "subpools" of users (’099 Patent, col. 2:61-63; col. 8:5-14).
• Technical Importance: The claimed method provides a technical framework for moving beyond static chat rooms to dynamic, user-configurable communication environments that more closely replicate the complexity of real-world social interactions (’099 Patent, col. 1:51-65).

Key Claims at a Glance

• The complaint asserts claims 1-20 of the ’099 patent (Compl. ¶8).
• Independent Claim 1 (Method) recites a method for executing multimedia communication, 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.
  • This "virtual subscriber profile" is used to freely define a "mode of a subscriber selection", a communication type, number of links, or data transmission type.
  • The "subscriber selection mode" includes a "random process" for connecting to another random subscriber.
  • The "subscriber selection mode" also includes an "activatable call procedure" for connecting to a subscriber from a selection list, where these subscribers form "subscriber sub-pools".

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, methods, or services. It generally accuses "systems, products, and services that facilitate multimedia communication, in particular video, audio, and/or text chat between terminals" operated by the Defendant (Compl. ¶8).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the specific functionality of the accused instrumentalities. It alleges that the Defendant’s systems allow for multimedia communication and that the Defendant provides instructions to customers on how to use these features (Compl. ¶¶8, 10, 11).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s systems directly infringe claims 1-20 of the ’099 patent (Compl. ¶8). It states that support for these allegations is found in a chart attached as Exhibit B (Compl. ¶9). As Exhibit B was not included with the complaint provided for this analysis, a detailed, element-by-element examination of the infringement allegations is not possible. The complaint’s narrative theory is that by maintaining and operating systems that facilitate multimedia chat, Defendant has put the inventions of the ’099 patent into service (Compl. ¶8).

• Identified Points of Contention: Based on the patent’s claims and the general nature of the allegations, the infringement analysis may raise several key questions:
  • Scope Questions: The infringement case may turn on whether a standard user account or customer service chat interface in a commercial product can be considered a "virtual subscriber profile" as defined by the patent. A central question is whether Defendant’s systems allow a user profile to "freely define" the "mode of a subscriber selection" in the manner claimed, or if communication options are pre-determined by the system's design.
  • Technical Questions: A factual dispute may arise over whether the accused systems implement specific features like a "random process" for establishing a communication link, as required by claim 1. It also raises the question of what evidence demonstrates that Defendant’s systems create and manage "subscriber sub-pools" based on user classifications and contacts, as opposed to implementing simpler features like a friends list.

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 pillar of the invention; its construction will be critical for determining the scope of the claims. The infringement dispute will likely focus on whether Defendant’s user accounts or similar features meet the functional requirements of a "virtual subscriber profile." Practitioners may focus on this term because it appears to require more than a simple user account with login credentials; it is the mechanism through which the user actively defines the rules of engagement for communication.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the account in general terms as including "login data, contacts, the profile, switching and management-relevant data and other entries" (’099 Patent, col. 2:45-48), which could be argued to cover a wide range of modern user accounts.
  • Evidence for a Narrower Interpretation: The claims and specification repeatedly link the profile to specific, inventive functions: "By means of this setting-up process a mode of a subscriber selection preceding the communication, a communication type and/or a number of communication links... are freely defined" (’099 Patent, col. 2:27-31). This suggests the term may be limited to profiles that provide this specific suite of user-configurable controls.

• The Term: "subscriber sub-pool"

• Context and Importance: This term is essential to the claimed method of organizing users and defining connection possibilities. The dispute may center on whether a simple contact list or group chat qualifies as a "subscriber sub-pool".

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent states that "subscribers are logically grouped according to specific criteria," which could potentially read on any grouping of users within a system (’099 Patent, col. 8:9-10).
  • Evidence for a Narrower Interpretation: Claim 1 requires that subscribers in a selection list form "at least one of an open and a closed subscriber sub-pool." The specification provides specific examples, such as a "first subpool 11a... in a single-connect" and a "second subpool 11b for a multi-connect," as well as an "isolated subpool 11e... on a blacklist" (’099 Patent, col. 8:10-18). This may support a narrower construction requiring distinct, functionally-defined groups beyond a generic contacts list.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant "actively encouraged or instructed others (e.g., its customers)" on how to use its products and services in an infringing manner (Compl. ¶10). For contributory infringement, it alleges Defendant provides instructions through its website and manuals, that the product's only reasonable use is infringing, and that it is not a staple commercial product (Compl. ¶11).
• Willful Infringement: The complaint alleges knowledge of the ’099 patent from "at least the filing date of the lawsuit" (Compl. ¶¶10, 11). The prayer for relief requests a finding of willfulness and treble damages if discovery reveals that Defendant had pre-suit knowledge of the patent (Compl. p. 7, ¶e).

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

The resolution of this case will likely depend on the answers to a few central questions for the court:

1. A core issue will be one of definitional scope: can the term "virtual subscriber profile," which the patent describes as a tool for a user to "freely define" multiple communication and selection modes, be construed to cover the user account functionalities within Defendant’s accused systems?

2. A key evidentiary question will be one of technical implementation: what evidence will Plaintiff present to demonstrate that Defendant’s general-purpose communication products perform the specific, unconventional methods recited in the claims, such as initiating connections via a "random process" or organizing users into dynamic, functionally distinct "subscriber sub-pools"?