IP Law Daily, PATENT—E.D. Tex.: Dismissal with prejudice granted in chat technology dispute, (Mar 9, 2026)

By Kevin M. Finson, J.D.

The court found the claim “merely takes the concept of striking up a random conversation in the real world and implements it through existing online chat technology.”

A federal court in the Eastern District of Texas has dismissed, with prejudice, an infringement suit brought by a patent owner against a credit union, finding the asserted patent invalid under 35 U.S.C. § 101. The court found that the technology merely implemented the concept of random conversations using existing computer technology (Random Chat, LLC v. Altra Federal Credit Union, No. 2:25-cv-00478-JRG (E.D. Tex. Mar. 6, 2026)).

Random Chat, LLC (Random) is the owner of U.S. Patent No. 8,402,099 (the ’099 patent), which claimed “methods and apparatuses for executing multimedia communication, particular video, audio, and/or text chat between terminals.” Random brought suit for infringement against Altra Federal Credit Union (Altra) for infringement. Altra moved to dismiss on the ground that the asserted patent was invalid for being directed at an abstract idea. The parties agreed claim 1 was representative for the purposes of the motion. After noting that neither party had requested claim construction, the court applied the two-step Alice test.

Abstract idea. On step one of the Alice test, Altra argued that the representative claim covered only the abstract idea of “setting up an online chat session with a random person” and did so using conventional components and processes, including things such as a “communication network,” “subscriber profile,” and “communication link.” Random argued that the focus of the claim was, instead, “a random process for setting up a communication link between a selecting terminal of a first subscriber profile to at least another terminal of a random subscriber profile” and did so by solving technological problems in the prior art relating to establishing connections. The court found that the claim merely implemented the concept of striking up a conversation in the real world and implemented it through existing technology.

Inventive concept. The court found that there was no inventive concept present which could save the patentability of the claim because it merely implemented the abstract idea using conventional computer components. Allegations by Random that its claim was in fact directed to an improvement over existing technology were conclusory and not sufficiently pleaded.

The court granted the motion to dismiss and denied leave to amend, finding that amendment would be futile.

The Case is No. 2:25-cv-00478-JRG.

Judge: Gilstrap, J.

Attorneys: William P. Ramey, III (Ramey LLP) for Random Chat, LLC. Michael Alden Vincent (Fish & Richardson P.C.) for Altra Federal Credit Union.

Companies: Random Chat, LLC; Altra Federal Credit Union

Cases: Patent TechnologyInternet TexasNews