Arendi S.A.R.L. v. Oath Holdings Inc.

• Court: Court of Appeals for the Federal Circuit
• Decided: June 4, 2026
• Docket: 22-1762
• Status: Unpublished

Opinion

Case: 22-1762 Document: 107 Page: 1 Filed: 06/04/2026

NOTE: This disposition is nonprecedential.

United States Court of Appeals for the Federal Circuit ______________________

ARENDI S.A.R.L., Plaintiff-Appellant

v.

OATH HOLDINGS INC., OATH INC., Defendants-Appellees ______________________

2022-1762 ______________________

Appeal from the United States District Court for the District of Delaware in No. 1:13-cv-00920-VAC-JLH, Judge Leonard P. Stark. -------------------------------------------------

APPLE INC., Third-Party Defendant

GOOGLE LLC, Defendant-Appellee ______________________

2023-2029, 2026-1451 Case: 22-1762 Document: 107 Page: 2 Filed: 06/04/2026

______________________

Appeals from the United States District Court for the District of Delaware in No. 1:13-cv-00919-JLH, Judge Jen- nifer L. Hall. ______________________

Decided: June 4, 2026 ______________________

JOHN PIERRE LAHAD, Susman Godfrey LLP, Houston, TX, argued for plaintiff-appellant. Also represented by SETH ARD, MAX ISAAC STRAUS, New York, NY; KEMPER DIEHL, Seattle, WA; KALPANA SRINIVASAN, Los Angeles, CA.

JEFFRI A. KAMINSKI, Venable LLP, Washington, DC, ar- gued for defendants-appellees Oath Holdings Inc., Oath Inc. Also represented by FRANK C. CIMINO, JR., MEGAN S. WOODWORTH.

GINGER ANDERS, Munger, Tolles & Olson LLP, Wash- ington, DC, argued for defendant-appellee Google LLC. Also represented by VINCENT LING, Los Angeles, CA; EVAN JENNINGS MANN, San Francisco, CA. ______________________

Before DYK, LINN, and HUGHES, Circuit Judges. LINN, Circuit Judge. Arendi S.A.R.L. (“Arendi”) appeals from final judg- ments of the United States District Court for the District of Delaware holding that Google LLC (“Google”) and Oath Holdings Inc. (“Oath”) do not infringe the asserted claims of U.S. Patent No. 7,917,843 (the “’843 patent”) and that those claims are invalid as both anticipated and obvious over the prior art, and from the court’s grant of judgment on the pleadings under Federal Rule of Civil Procedure Case: 22-1762 Document: 107 Page: 3 Filed: 06/04/2026

ARENDI S.A.R.L. v. OATH HOLDINGS INC. 3

12(c) holding that the asserted claims of U.S. Patents No. 7,496,854 (the “’854 patent”), No. 7,921,356 (the “’356 patent”), and No. 8,306,993 (the “’993 patent”) are di- rected to patent-ineligible subject matter under 35 U.S.C. § 101. See Arendi S.A.R.L. v. Google LLC, No. 13-cv-919, Dkt. No. 616 (D. Del. Feb. 2, 2024) (“Final Judgment”); Ar- endi S.A.R.L. v. Google LLC, No. 13-cv-919, Dkt. No. 625 (D. Del. Jan. 14, 2026) (“Amended Final Judgment”); Ar- endi S.A.R.L. v. Google LLC, No. 13-cv-919, Dkt. No. 201 (D. Del. Jan. 2, 2020) (“Rule 12(c) Order”). Google argues as an alternative ground for affirmance that the ’843 pa- tent is also directed to patent ineligible subject matter un- der section 101. For the following reasons, we affirm and hold that the asserted claims of each of the four patents claim patent ineligible subject matter under section 101. Accordingly, we do not reach the other issues. BACKGROUND Arendi filed two related infringement suits in the Dis- trict of Delaware, one against Google and one against Oath. Arendi alleged that Google infringed the ’843 patent, the ’854 patent, the ’356 patent, and the ’993 patent. Arendi alleged that Oath infringed the ’843 patent, the ’356 pa- tent, and the ’993 patent. The ’843, ’356, and ’854 patents share a common speci- fication. The ’993 patent has a similar specification and is directed to similar subject matter. The asserted patents generally concern identifying information in a document and using that information to search for related infor- mation in an external source, such as a contact database. See ’843 patent col. 1 l. 16–col. 2 l. 40. The parties treat claim 1 of the ’843 patent, claim 93 of the ’854 patent, claim 2 of the ’356 patent, and claim 1 of the ’993 patent as representative. Since we write for the parties, we assume familiarity with the representative claim language. Case: 22-1762 Document: 107 Page: 4 Filed: 06/04/2026

After claim construction, Google and Oath moved for judgment on the pleadings under Rule 12(c), arguing that the asserted claims were directed to patent-ineligible sub- ject matter under 35 U.S.C. § 101. Rule12(c) Order at 5–6. The district court granted the motion as to the representa- tive claims of the ’854, ’356, and ’993 patents, but denied the motion as to the ’843 patent. Id. at 2. The case then proceeded on the ’843 patent. Google moved for summary judgment of noninfringement as to as- serted claims 23 and 30 of the ’843 patent. The district court granted the motion as to Google’s Linkify and Smart Linkify products because the alleged “documents” were not editable but denied the motion as to other Google products. Oath separately moved for summary judgment of nonin- fringement of claim 23 of the ’843 patent. The district court granted Oath’s motion, concluding that Arendi had not shown that Oath directly infringed the asserted computer- readable-medium claim. The district court then entered judgment in favor of Oath, and Arendi appealed. The remaining Google claims proceeded to trial. The jury found that Arendi had not proven that Google in- fringed claims 23 or 30 of the ’843 patent and that Google had proven by clear and convincing evidence that those claims were invalid as anticipated and obvious. See Arendi S.A.R.L. v. Google LLC, No. 13-cv-919, 2024 WL 406405, at *1 (D. Del. Feb. 2, 2024) (“JMOL Order”). Arendi moved for judgment as a matter of law on anticipation and obvi- ousness. Id. at *2. The district court denied Arendi’s mo- tion, noting that because Google did not seek a declaratory judgment of invalidity, the Court “has discretion to not con- sider Arendi’s [invalidity] arguments” and elects to exer- cise that discretion to avoid “a waste of judicial resources.” Id. at *2–3. The district court then entered a judgment stating that “[j]udgment is entered in favor of Defendant and against Plaintiff on Plaintiff’s claim of patent infringe- ment of U.S. Patent No. 7,917,843.” Final Judgment at 1. Arendi appealed. Case: 22-1762 Document: 107 Page: 5 Filed: 06/04/2026

ARENDI S.A.R.L. v. OATH HOLDINGS INC. 5

After oral argument, we ordered the parties to seek clarification from the district court as to whether the judg- ment rested on noninfringement alone or also incorporated the jury’s invalidity verdict. The district court entered an amended final judgment clarifying that the jury found non- infringement, anticipation, and obviousness as to claims 23 and 30 of the ’843 patent, and that “all of the jury’s findings remain undisturbed and have not been set aside.” Amended Final Judgment, at 1. Arendi timely appealed the amended judgment. We then consolidated the appeals and ordered supplemental briefing concerning Arendi’s ap- peal from the amended judgment. DISCUSSION I The parties devote substantial attention to the scope of the district court’s final judgment and, relatedly, to what issues are properly before us on appeal. In particular, the parties initially disputed whether the judgment as to the ’843 patent rested solely on noninfringement or also incor- porated the jury’s invalidity findings. The district court’s amended judgment resolves that dispute. It clarifies that, as to the ’843 patent, the jury found both noninfringement and invalidity, and that “all of the jury’s findings remain undisturbed and have not been set aside.” Amended Final Judgment at 1. Thus, the judg- ment rests on both infringement and invalidity grounds as independent bases for judgment. Both infringement and invalidity are therefore before this court on appeal. Google has preserved its invalidity arguments on ap- peal as to the ’843 patent. Google argued in its initial re- sponse brief that, like the other asserted patents, the ’843 patent is directed to ineligible subject matter, and it renewed that position in supplemental briefing following the amended judgment. Google Br. 36–39; Google Supp. Br. 5. Case: 22-1762 Document: 107 Page: 6 Filed: 06/04/2026

We have recognized that patent eligibility under § 101 is a ground of invalidity. Astellas Pharma, Inc. v. Sandoz Inc., 117 F.4th 1371, 1378 (Fed. Cir. 2024). Where, as here, the judgment as to the ’843 patent rests in part on invalid- ity, determining that the asserted claims are directed to patent-ineligible subject matter may be considered as an alternative ground for affirmance. See TypeRight Key- board Corp. v. Microsoft Corp., 374 F.3d 1151, 1156–57 (Fed. Cir. 2004). We turn next to the issue of patent eligi- bility as to all four patents. II A We begin with Arendi’s challenges to the district court’s analysis under Alice/Mayo step one. See Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 573 U.S. 208, 217 (2014); Mayo Collaborative Servs. v. Prometheus Lab’ys, Inc., 566 U.S. 66, 77–78 (2012). The district court held that the asserted claims of the ’356, ’854, and ’993 patents are di- rected to patent-ineligible subject matter but that repre- sentative claim 1 of the ’843 patent is not directed to patent-ineligible subject matter. Rule12(c) Order at 7–9. The district court distinguished the ’843 patent because, in its view, claim 1 captured the “purported inventive concept of beneficial coordination” between a first computer pro- gram displaying a document and a second computer pro- gram searching an external information source. Id. at 8. Arendi argues that the district court erred by holding the asserted claims of the ’356, ’854, and ’993 patents inel- igible because those claims, like the ’843 patent, are di- rected to an improvement in computer functionality. Arendi contends that the asserted claims improve com- puter functionality by allowing a user to retrieve infor- mation from an external source while working within a document and by reducing the number of user steps needed to initiate the search. Case: 22-1762 Document: 107 Page: 7 Filed: 06/04/2026

ARENDI S.A.R.L. v. OATH HOLDINGS INC. 7

Google contends that all four asserted patents are di- rected to the same abstract idea: identifying information in a document, using that information to search for related information in an external source, and using the results of that search. We agree with the district court that the asserted claims of the ’356, ’854, and ’993 patents are directed to an abstract idea. Rule12(c) Order at 7–9. Those claims recite the same basic process: identifying information in a docu- ment, using that information to search for related infor- mation in an external source, and using the results of that search to perform some action. See ’356 patent claim 2; ’854 patent claim 93; ’993 patent claim 1. Specifically, the representative claims recite “analyzing” textual infor- mation in a document, “identifying” that information as a type that can be searched, “using” that information to search a database or other information source, and “per- forming” an action based on the retrieved information. ’356 patent claim 2; ’854 patent claim 93; ’993 patent claim 1. Those steps amount to collecting information, analyzing the collected information, retrieving related information, and using the result. We have long held that claims directed to “collecting information, analyzing it, and displaying certain results of the collection and analysis” are abstract. Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1353–54 (Fed. Cir. 2016). We likewise “have repeatedly held claims ‘directed to collection of information, comprehending the meaning of that collected information, and indication of the results, all on a generic computer network operating in its normal, ex- pected manner’ to be abstract.” Int’l Bus. Machs. Corp. v. Zillow Grp., Inc., 50 F.4th 1371, 1378 (Fed. Cir. 2022) (quoting In re Killian, 45 F.4th 1373, 1380 (Fed. Cir. 2022)). The asserted claims of the ’356, ’854, and ’993 patents re- cite the functional results of identifying, searching, and acting on information without specifying how those results are achieved in a way that improves computer Case: 22-1762 Document: 107 Page: 8 Filed: 06/04/2026

functionality. See Zillow, 50 F.4th at 1378; Elec. Power, 830 F.3d at 1354. Arendi’s contrary arguments do not persuade us. Ar- endi contends that the claims improve computer function- ality by making it more convenient for users to retrieve information while working in a document. But “improving a user’s experience while using a computer application is not, without more, sufficient to render the claims directed to an improvement in computer functionality.” Custome- dia Techs., LLC v. Dish Network Corp., 951 F.3d 1359, 1365 (Fed. Cir. 2020). The representative claims of the ’356, ’854, and ’993 patents do not recite a specific technical solution to a technological problem but instead use generic computer functionality as a tool to carry out an abstract information-processing task. See Elec. Power, 830 F.3d at 1354; Customedia Techs., 951 F.3d at 1365. Moreover, we hold that the ’843 patent is not meaning- fully different from the ’356, ’854, and ’993 patents for pur- poses of step one because it recites the same abstract process as the other asserted patents. Compare ’843 patent claim 1, with ’356 patent claim 2; ’854 patent claim 93; ’993 patent claim 1. As the district court recognized, claim 1 of the ’843 patent is directed to displaying a document, analyzing information in that document, searching an ex- ternal source using a second computer program, and using the result to perform an action. Rule12(c) Order at 7. That is the same abstract process of collecting, analyzing, searching, and using information that underlies the ’356, ’854, and ’993 patents. See Elec. Power, 830 F.3d at 1353–54; Zillow, 50 F.4th at 1378. The district court’s contrary conclusion rested on its characterization of the ’843 patent as reciting “beneficial coordination” between a first computer program displaying a document and a second computer program searching an external information source. Rule12(c) Order at 7–8. But “beneficial coordination” does not appear in the claims or Case: 22-1762 Document: 107 Page: 9 Filed: 06/04/2026

ARENDI S.A.R.L. v. OATH HOLDINGS INC. 9

the specification. See generally ’843 patent. Rather, the phrase originates from a prior decision of this court ad- dressing obviousness, not patent eligibility. Arendi S.A.R.L. v. Apple Inc., 832 F.3d 1355, 1357–62 (Fed. Cir. 2016). But even to the extent the claims implicitly require such coordination, the purported benefit merely amounts to little more than a reiteration of other claim limitations directed to the retrieval of information from a second com- puter program while the user is at work in a document in the first computer program and does not justify a different conclusion on eligibility. Rule12(c) Order at 7–8. The claims of the ’843 patent call for using “computers . . . as tools to carry out an abstract idea, using their ordinary functions without specific hardware or process advances in those functions—e.g., receiving inputs, storing and retriev- ing, processing, outputting (including displaying), and transmitting.” See GoTV Streaming, LLC v. Netflix, Inc., 166 F.4th 1053, 1064 (Fed. Cir. 2026); Elec. Power, 830 F.3d at 1354. While a specific technique for coordinat- ing two programs may in certain circumstances be patent eligible, here, claim 1 of the ’843 patent does not describe “a concrete asserted improvement in how” the two com- puter programs work together while allowing the docu- ment to stay displayed. See GoTV Streaming, 166 F.4th at 1064. Thus, “beneficial coordination” itself is an ab- stract idea and does not make claim 1 of the ’843 patent any less abstract. Arendi’s reliance on the claimed “input device” does not alter that conclusion. Arendi argues that the input device provides a technological improvement by allowing the user to initiate the search with fewer commands. But reducing the number of user steps, without more, does not render a claim non-abstract. See Data Engine Techs. LLC v. Google LLC, 906 F.3d 999, 1008–12 (Fed. Cir. 2018); Customedia Techs., 951 F.3d at 1365. In Data Engine, we distinguished claims directed to a specific notebook-tabbed interface, which were patent eligible, from claims that more Case: 22-1762 Document: 107 Page: 10 Filed: 06/04/2026

generally recited associating spreadsheets with identifiers which were not patent eligible, because the latter were not limited to a particular technical implementation. 906 F.3d at 1008–12. Here, the ’843 patent does not claim any spe- cific structure or mechanism for the input device. The spec- ification describes an example input device as “a button 42 in a word processor” and explains that the invention may be practiced with “all types of input devices,” including “a touch screen, keyboard button, icon, menu, voice command device,” and others. ’843 patent col. 10 ll. 9–12. This lan- guage, however, invokes generic structures rather than specific improvements in computer functionality. See Data Engine, 906 F.3d at 1012–13; Customedia Techs., 951 F.3d at 1365. The ’843 patent claims thus more closely resemble those we found patent ineligible in Data Engine than they do those we found patent eligible. See Data Engine, 906 F.3d at 1012; see also ’843 patent claim 1. Accordingly, we conclude that the asserted claims of the ’356, ’854, ’993, and ’843 patents are directed to an ab- stract idea at Alice/Mayo step one. B We next consider Arendi’s challenges to the district court’s analysis under Alice/Mayo step two. At this step, we ask whether the claims contain an “inventive concept” sufficient to “transform the nature of the claim” into a pa- tent-eligible application. Alice, 573 U.S. at 217. The dis- trict court concluded that the asserted claims of the ’356, ’854, and ’993 patents do not contain such an inventive con- cept. Rule12(c) Order at 8–9. The court did not reach step two for the ’843 patent because it found those claims not directed to an abstract idea at step one. Rule12(c) Order at 8. Arendi argues that the district court erred because the claim elements, individually and as an ordered combina- tion, recite an inventive concept in the form of improved computer functionality—specifically, enabling Case: 22-1762 Document: 107 Page: 11 Filed: 06/04/2026

ARENDI S.A.R.L. v. OATH HOLDINGS INC. 11

coordination between programs and reducing the number of user steps required to retrieve information. Arendi fur- ther contends that these same concepts apply equally to the ’843 patent and render those claims patent eligible. Google responds that the asserted claims of all four patents merely implement the abstract idea of using generic computer components performing conventional functions and there- fore lack any inventive concept. We agree with the district court that the asserted claims of the ’356, ’854, and ’993 patents do not recite an inventive concept. Rule12(c) Order at 8–9. As the district court found, those claims are implemented using generic computer components performing conventional functions— analyzing information, identifying search terms, querying a data source, and using the results. Rule12(c) Order at 7–9. Arendi’s purported improvements—facilitating inter- action between programs and reducing user steps—simply restate the abstract idea identified at step one. “It has been clear since Alice that a claimed invention’s use of the ineli- gible concept to which it is directed cannot supply the in- ventive concept.” BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1290 (Fed. Cir. 2018). Nor does implement- ing that idea on generic computer components supply an inventive concept. See Alice, 573 U.S. at 223. The district court therefore correctly concluded that the ’356, ’854, and ’993 patents lack an inventive concept. Rule12(c) Order at 8–9. The same analysis applies to the ’843 patent. Although the district court did not reach step two for the ’843 patent, its findings regarding the nature of the claimed functions apply equally here. Rule12(c) Order at 7–9. Claim 1 of the ’843 patent recites the same sequence of functions identi- fied by the district court with respect to the related pa- tents—displaying a document, analyzing information in that document, searching an external source using a Case: 22-1762 Document: 107 Page: 12 Filed: 06/04/2026

second program, and using the results to perform an ac- tion—all implemented using conventional computer func- tionality. Rule12(c) Order at 7; ’843 patent claim 1. Arendi’s reliance on “beneficial coordination” does not supply an inventive concept. As discussed above, that is not a claim limitation, and the concept describes the same abstract idea underlying the claims. See Rule12(c) Order at 7–8. It therefore cannot provide the “significantly more” required at step two. See BSG Tech, 899 F.3d at 1290. Nor does the claimed “input device” alter the analysis. The district court found that the asserted claims rely on generic computer components, and the shared specification confirms that the input device may take any conventional form. Rule12(c) Order at 6–9; ’843 patent col. 10 ll. 9–12. The claims do not require any particular technological im- plementation of that device. ’843 patent claim 1. Considering the elements as an ordered combination likewise does not supply an inventive concept. The district court determined that materially similar claim elements, arranged in the same sequence of functions, did not amount to an inventive concept for the related patents. Rule12(c) Order at 8–9. The ’843 patent adds no claimed technical mechanism or nonconventional arrangement that would change that conclusion. See ’843 patent col. 10 l. 38–col. 16 l. 5. Accordingly, based on the district court’s findings and the claim language before us, we conclude that the asserted claims of the ’843 patent, like those of the ’356, ’854, and ’993 patents, do not recite an inventive concept and are pa- tent ineligible under § 101. Because we conclude that the asserted claims of the ’356, ’854, ’993, and ’843 patents are patent ineligible under § 101, we need not reach the parties’ remaining ar- guments regarding infringement, claim construction, an- ticipation, or obviousness. Case: 22-1762 Document: 107 Page: 13 Filed: 06/04/2026

ARENDI S.A.R.L. v. OATH HOLDINGS INC. 13

CONCLUSION We have considered Arendi’s remaining arguments and find them unpersuasive. For these reasons, we affirm the district court’s judgment. AFFIRMED