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GoTV v. Netflix: Labels Are Not Structure

Federal Circuit, decided 9 February 2026. Read from the decision; quotations verified against its text.

Read this with Contour v. GoPro. Without Contour, the "labels are not structure" lesson reads as an impossible standard. Contour is where structural limitations existed and the claims survived.
Holding

On February 9, 2026 the Federal Circuit held GoTV's device-tailoring patents ineligible on Netflix's cross-appeal, wiping out a $2.5 million jury verdict, and explained that pointing to an "algorithm," an "architecture," or "specific data structures" in a claim does not help when those labels carry no structural detail.

GoTV patented delivering content to a phone after tailoring the presentation to that device's screen and capabilities. A jury said Netflix infringed and awarded $2.5 million. The Federal Circuit reversed on Netflix's cross-appeal and entered judgment for Netflix.

The most useful passage for engineers is where the court works through GoTV's own vocabulary. "Algorithm" and "architecture" are "highly general labels" without details behind them, and "specific data structures" fails because the claim terms "do not call for anything about the 'structure'" of the data.

The court illustrated what would have counted with examples like header and payload, or bit-slot assignments. It compared the claimed idea to a dress pattern or a kitchen-cabinet blueprint.

GoTV did win one point: the court reversed the ruling that some of its claims were indefinite. It made no difference.

What This Case Is Not

The header/payload line is an illustration, not a requirement. It is quotable enough to invite being turned into a drafting rule. The court offered it as an example of what would have counted on these facts. It is not a checklist item, and reciting those words would not by itself have changed the outcome.
  • It does not hold that data-structure claims are ineligible.
  • It does not establish how much structural detail is enough.
  • It does not tell you whether your claim terms carry structure. That reading belongs to counsel with the claims in hand.

Educational, not legal advice. Whether any particular claim is eligible under § 101 is a legal conclusion a qualified patent attorney reaches on the actual claims.

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