Despite motor reduction due to rehabilitation training, whether robot-mediated or otherwise, many stroke patients with hemiplegia have learn non-use and lack motivation to use their impaired arm in real life. Therefore, other factors besides motor impairment and strength levels are critical to recovery of function on real activities. This paper discusses barriers to impaired arm use in the real world and presents a definition of motivation that is relevant to robot-assisted therapy. Three case studies highlighting three strategies to create robotic systems that are more motivating are discussed. The strategies are 1: embed therapy within a framework that provides patients with monitoring and interaction with therapists, 2: embed therapy into fun, video game like activities, and 3: embed therapy within patient-centered real-life functional activities