Solution to the "Flat Serve" problem, of no upward arc.

2026 Rule:

7.C Volley Serve. The service motion for a volley serve must comply with Rules 7.C.1 through 7.C.4.
7.C.1 Upward Arc. The server’s paddle must be moving in a clear upward arc when the paddle contacts the ball.
7.C.2 Paddle Head. The highest point of the paddle head must clearly not be above the highest part of the server’s wrist joint when the paddle contacts the ball.
7.C.3 Ball Height. The ball must clearly be no higher than the server’s waist when the paddle contacts the ball.

2025 Rules:

Approve the change to 4.A.7.a as submitted. Also add “clearly” to Rules 4.A.7.b and 4.A.7.c. The server’s paddle must be moving in a clearly upward arc at the time the ball is struck with the paddle. (See Figure 4-3.)
4.A.7.b. The highest point of the paddle head must clearly not be above the highest part of the wrist (where the wrist joint bends) when the paddle strikes the ball. (See Figures 4-1 and 4-2.)
4.A.7.c. Contact with the ball must clearly not be made above the waist. (See Figures 4-1 and 4-3.)

4.A.7.a. The server’s paddlearm must be moving in an clearly upward arc at the time the ball is struck with the paddle. (See Figure 4-3.)

4.A.7.a. The server’s arm must be moving in an upward arc at the time the ball is struck with the paddle. (See Figure 4-3.)

4 A 7 A has always been problematic. As written a 1% angle of "low to high" meets the rule, yet to 99.% of all normal human referees, this looks FLAT. So does 2%, 3%, keep going until you can notice "clearly" the paddle going in an upward arc at the time of the strike of the ball.

Also, change "Arm" to "Paddle" or "Paddle Face" if needed. Regardless, I think this would make referee live easier. The magic word: Clearly!

Volley serves