The US Court of Appeals for the Federal Circuit reversed a district court’s rejection of Netflix’s 35 U.S.C. § 101 challenge, finding that claims directed to tailoring content specifications for wireless devices were patent ineligible. GoTV Streaming, LLC v. Netflix, Inc., Case Nos. 24-1669; -1744 (Fed. Cir. Feb. 9, 2026) (Prost, Clevenger, Taranto, JJ.)

GoTV sued Netflix for direct and induced infringement of three related patents directed to server-based tailoring of content for wireless devices. The district court dismissed the induced infringement claims and rejected Netflix’s § 101 challenge. A jury found infringement of one of the asserted patents and awarded $2.5 million in damages. Netflix appealed.

The Federal Circuit reversed the district court’s indefiniteness ruling as to a key term of the representative patents and adopted GoTV’s proposed construction of that claim term: “discrete low level rendering command.” Based on its construction, the Court concluded that the asserted claims were directed to an abstract idea and lacked an inventive concept under Alice. The Court concluded that the claims merely recited the abstract idea of using a generic template tailored to a user’s device constraints and relied on conventional computer and network functions without specifying a concrete technological improvement. The Federal Circuit determined that the claims failed both steps of the Alice framework and were invalid under § 101.

Although its § 101 holding resolved the case in Netflix’s favor, the Federal Circuit vacated the district court’s summary judgment of no inducement and its denial of GoTV’s motion for a new trial on damages, explaining that GoTV had presented substantial arguments on those issues, before directing entry of final judgment for Netflix.

Practice note: The Federal Circuit noted that the ineligibility analysis depends on the claim language at issue, not whether there may be a patent eligible invention disclosed in the specification. Although the prosecution history may be intrinsic evidence for claim construction, recitation of the problems faced by the inventor and the inventive solution cannot be relied on to argue unclaimed details of the invention to render an abstract idea patent eligible.