Finally, a BCI-controlled FES orthosis can be also relevant for motor recovery of the upper extremities in stroke patients. Despite the fact that there is no literature available on the use of such a type of device in this patient population, some studies on the topic of FES training have emerged recently. For example, Hara (2008) claims that user-driven electrical muscle stimulation – but not machine-paced electrical muscle stimulation – improves the motor function of the hemiparetic arm and hand. A new hybrid FES therapy comprising proportional EMG-controlled FES and motor point block for antagonist muscles have been applied with good results in an outpatient rehabilitation clinic for patients with stroke. Additionally, Hara et al. (2008) have shown that a daily task-oriented FES home therapy program can effectively improve wrist and finger extension and shoulder flexion. Furthermore, proprioceptive sensory feedback might play an important role in this kind of therapy. The results of the single-case study from Page et al. (2009) supports these promising results. Moreover, another recent single-case study supports the benefit of a combination of FES and BCI (Daly et al., 2009). However, this use of BCI plus FES in the field of motor recovery has to be investigated more extensively.