Does the cell phone have to have a voice recording feature for it to infringe?

In this case since the focus was stated to be the '774 patent, I believe the answer to that would be yes.

However, you need to realize how very many cell phone models LG has made and sold through the years - and how many (even some of the least expensive) models have voice-recording capability even if it isn't meant for saving voice messages per se. For example, I once owned an LG phone which let me record my voice for the voice-activated dial feature. Ka-ching!

Now I would argue that even if it recorded to internal flash, ANY voice recording to flash should still infringe under '774... but I could be wrong about that and maybe DM read it another way. We'll see.

- Sinkman