Arendi S.a.r.l. v. Oath Holdings Inc., Oath Inc.

N OTE: This disposition is nonprecedential.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.
-------------------------------------------------
ARENDI S.A.R.L.,
Plaintiff-Appellant
APPLE INC.,
Third-Party Defendant
v.
GOOGLE LLC,
Defendant-Appellee
______________________
2023-2029, 2026-1451
Case: 22-1762 Document: 107 Page: 1 Filed: 06/04/2026

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ARENDI S. A. R. L. v. OATH HOLDINGS INC. 2
______________________
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
______________________
J OHN P IERRE L AHAD, Susman Godfrey LLP, Houston,
TX, argued for plaintiff-appellant. Also represented by
SETH ARD, MAX I SAAC STRAUS , New York, NY; K EMPER
D IEHL , Seattle, WA; K ALPANA SRINIVASAN , Los Angeles,
CA.
J EFFRI A. K AMINSKI, Venable LLP, Washington, DC, ar-
gued for defendants-appellees Oath Holdings Inc., Oath
Inc. Also represented by F RANK C. CIMINO, J R., MEGAN S.
WOODWORTH .
G INGER A NDERS , Munger, Tolles & Olson LLP, Wash-
ington, DC, argued for defendant-appellee Google LLC.
Also represented by VINCENT L ING, Los Angeles, CA; EVAN
J ENNINGS M ANN, San Francisco, CA.
______________________
Before D YK, L INN, and HUGHES , Circuit Judges.
L INN, 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
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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.
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ARENDI S. A. R. L. v. OATH HOLDINGS INC. 4
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.
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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.
D ISCUSSION
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.
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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.
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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
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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
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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
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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
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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
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ARENDI S. A. R. L. v. OATH HOLDINGS INC. 12
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.
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CONCLUSION
We have considered Arendi’s remaining arguments
and find them unpersuasive. For these reasons, we affirm
the district court’s judgment.
AFFIRMED
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