Federal Circuit Stresses Technical Improvement, Rejects Functional Claiming

Federal Circuit ruled US Patent No. 7,679,637 LLC's web conferencing patent invalid under 35 U.S.C. § 101 in case against Google LLC. Court found claims directed to abstract idea of asynchronous web conference review using purely functional language without technical improvement. Patent failed Alice test steps one and two, merely applying known time-shifting functions to conventional systems. Decision contrasted with GoPro case where concrete technological improvements supported patent eligibility.