Eastern District of Texas Tosses Random Chat's "Random Chat" Patent Under Section 101

If you defend patent lawsuits or have ever been a defendant, you've likely heard from Random Chat LLC – and certainly its counsel, Bill Ramey. Random Chat has sued many companies across technology, retail, e‑commerce, telecommunications and financial services.

Judge Rodney Gilstrap of the U.S. District Court for the Eastern District of Texas recently dismissed Random Chat's case with prejudice on Section 101 grounds. The court held that the asserted claims merely cover the idea of setting up a random chat and implement that idea with routine internet components.

The Order and the Posture

The decision came down from the Eastern District of Texas on March 6, 2026. Judge Gilstrap resolved eligibility at the pleadings stage – no claim construction needed, the parties agreed claim 1 was representative, and the court found amendment futile. Dismissal with prejudice followed.

What the Patent Actually Claims

The patent describes methods and systems for executing multimedia communications – video, audio and text chat – over a network using standard protocols such as TCP/IP or UDP. The representative claim centers on establishing a communication link between a selecting user and randomly selected counterpart. It references subscriber profiles, selection lists, a "random process" and an activatable call procedure.

The disclosures identify generic building blocks: terminals, mobile devices, browser-based multimedia components and servers running common scripting languages.

Step 1: Abstract Idea

The court focused on the claims' "character as a whole." Boiled down, this claim is about initiating a random chat connection. That concept is an organizing-human-activity idea that mirrors familiar offline behavior moved online. Labels such as "subscriber profile," "random process" and "selection list" do not change that. The claim states a desired result without reciting a specific technological way of achieving it. Prior decisions on online chat and information exchange point the same direction: Claiming a result is not claiming a method.

Step 2: No Inventive Concept

At step two, the court found nothing that transforms the abstract idea into a patent‑eligible application. Every component is conventional. The network is the internet. The terminals are ordinary PCs or web‑capable handhelds. The server runs routine scripting. The multimedia functionality comes through standard browser components. The patentee leaned on "random" matching and profile-based sub‑pooling, but the claim says nothing about how any of that works at a technical level. Without unconventional architecture or other technology baked into the claim, you have an abstract objective on routine computing. That does not clear Alice, as Judge Gilstrap ruled.

Disposition with Prejudice

The court denied leave to amend because eligibility turns on the claims, not pleading gloss. No allegation can rewrite claim language or convert generic components or technology into something nonroutine. When the representative claim can be implemented entirely with standard computer elements, there is no technological improvement to salvage. Dismissal with prejudice was the only result.

Why This Matters Beyond This Case

This is a clean Rule 12 decision from a court that handles a high volume of patent cases. It puts the emphasis on claim language, not specification rhetoric. It confirms that courts – including this one – can decide Section 101 early when the supposed invention is an ends‑oriented description running on ordinary infrastructure.

Practical Takeaways

For plaintiffs: Functional ends often do not survive without claimed technical means. High‑level references to "random processes," "selection lists" or "subscriber profiles" – untethered to a specific architecture or an algorithm – invite early dismissal. If the improvement is real, it should be in the claims.

For defendants: This opinion is a template, even in the Eastern District of Texas. Press representative claim treatment where the patentee cannot articulate meaningful differences. Show that the claim's building blocks are routine using the patent's own disclosures. Keep the focus on how the claim works, not what it aims to achieve.

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