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Results-Oriented Claims Still Fail Alice

Federal Circuit, decided 22 January 2026. Read from the decision; quotations verified against its text.

Holding

On January 22, 2026 the Federal Circuit affirmed dismissal of a web-conferencing patent as an abstract idea, holding that claims reciting what client applications are "arranged to allow" rather than how they achieve it are result-oriented, and in the process set out three distinct analytical approaches courts use to decide whether a software claim captures a technological improvement.

A patent on web conferencing with time-shifting, letting a participant rewind part of a presentation while the rest continues live, was thrown out on the pleadings and the Federal Circuit affirmed.

The claims described results: applications "arranged to allow" a participant to do things, a system "able to" record and replay simultaneously. What they never described was how any of it worked.

The court's most useful contribution is a list of three ways it decides these cases, including the observation that a claim "need not explicitly recite the improvement" so long as the improvement is genuinely embodied in it.

The patent owner's cleverest argument, that Google drafts its own patents the same way, got no traction at all.

What This Case Is Not

The three approaches are not a checklist you can run yourself. They describe how courts have analyzed claims. They are not a test a non-lawyer can apply to reach a conclusion about their own patent. Treat them as insight into what courts look at, and have counsel look at the actual claims.
  • It does not hold that functional language is always fatal.
  • It should not be quoted for a general proposition about where the improvement must appear. That question carries a live tension in the case law.
  • It does not tell you whether your claims are result-oriented.

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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