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In US Pat. No. 7,679,637 LLC v. Google LLC, No. 2024-1520, 2026 WL 174922 (Fed. Cir. Jan. 22, 2026), the Federal Circuit affirmed the district court's dismissal of the patentee's infringement claims, holding that the asserted web-conferencing "time-shifting" claims were patent-ineligible under § 101.
Patentee US Pat. No. 7,679,637 LLC sued Google for infringing its patent related to web conferencing systems enabling users to observe sessions in real-time, delayed during the session, or after the session has completed. Google moved to dismiss the complaint, arguing the asserted claims were patent-ineligible under § 101. The district court granted Google's motion.
On appeal, the Federal Circuit agreed under Alice Step One that the claims were directed to the abstract idea of playing back recorded content. The Court rejected patentee's argument that the claims were not result-oriented, finding that the claims did not describe how the system achieved the claimed functionality or improved prior-art technology. The specification reinforced this conclusion by characterizing the claimed components as conventional.
At Alice Step Two, the Court found no inventive concept because the claimed architecture and components were conventional and implemented using standard, off-the-shelf technology. The Court also rejected various procedural challenges raised by the patentee.
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