GoTV Streaming, LLC v. Netflix, Inc.

GoTV Streaming v. Netflix, decided February 9th, 2026. A panel of the Federal Circuit, in an opinion by Judge Taranto, reversed a jury verdict for the patent owner and held all three asserted patents ineligible under Section 101. The court held that claims directed to using a generic template that can be tailored to a device's display capabilities, carried out with ordinary computers and networks, are directed to an abstract idea and contain no inventive concept. Here's the brief.

GoTV Streaming owns three related patents that share a written description dating to 2007. They begin from a problem in the prior art: because wireless devices vary in screen size, resolution, and other properties, developers had been building applications from the ground up for each type of device — a costly, time-consuming process. The patents propose using a server to reduce that burden. When a user requests content, the server takes a generic template — a set of display specifications not specific to any device — and tailors it to the requesting device's screen size and other capabilities, then sends it on for the device to render.

GoTV sued Netflix in the Central District of California, alleging direct and induced infringement of all three patents. Before trial, the district court dismissed the inducement claims and rejected Netflix's argument that the patents were ineligible under Section 101. It also held the claims of one patent, the '865 patent, indefinite. A jury then found that Netflix infringed one claim of the '715 patent and awarded GoTV two-and-a-half million dollars.

Both sides appealed. Netflix cross-appealed the Section 101 ruling — and that challenge decided the case.

The question was whether the asserted claims are eligible for patenting under Section 101.

Courts apply the Supreme Court's two-step Alice test. Step one asks whether a claim is directed to an abstract idea. If it is, step two asks whether the claim recites an inventive concept that transforms it into something significantly more. GoTV treated claim 1 of the '865 patent as representative, so the court focused on that claim. Along the way, it reversed the district court's indefiniteness ruling, adopting GoTV's own claim construction before turning to eligibility.

At step one, the court held the representative claim directed to an abstract idea.

The court explained that its cases draw a line. On one side are claims that use computers and networks as tools to carry out an abstract idea, invoking their ordinary functions — receiving, storing, processing, and transmitting. On the other are claims that call for a concrete improvement in how those functions are carried out. GoTV's claims fell on the first side: they required no new hardware and no improvement to the wireless device's rendering, which the claim takes as a given.

At step two, the court found no inventive concept. Result-oriented functional language, generic computers, and speed-and-efficiency benefits do not supply one, and the court rejected GoTV's expert testimony as unable to save the claims.

All asserted claims were held invalid, and the court directed entry of judgment for Netflix.

GoTV Streaming applies settled Section 101 doctrine to device-tailored content delivery. It reaffirms that claims reciting a template adapted to a user's constraints, implemented with conventional servers and wireless devices, are directed to an abstract idea; that using such a template in a particular environment does not make an abstract idea concrete; that result-focused functional language describing what a system achieves, rather than how, does not carry a claim past step one; and that conclusory expert testimony cannot manufacture an inventive concept at step two. It sits alongside the court's line of computer-implemented eligibility cases, from Enfish and Alice through Broadband iTV and Recentive.

GoTV Streaming v. Netflix, decided February 9th, 2026. I'm John Goodhue. Thanks for watching.