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

Arendi S.A.R.L. v. Oath Holdings Inc. The Federal Circuit affirmed, holding that the asserted claims of all four patents, including the '843 patent on an alternative ground, are patent-ineligible under § 101. The claims were directed to the abstract idea of identifying information in a document, searching an external source, and using the results, and they lacked an inventive concept beyond generic computer implementation. The decision reinforces that workflow conveniences—such as cross-program lookup, fewer user steps, or generalized program coordination—do not save information-processing software claims without a claimed technical implementation. Affirmed. The court did not reach the remaining infringement, claim construction, anticipation, or obviousness issues. The patents generally involved identifying information in a document and using it to search an external source, such as a contact database, to retrieve related information. At Alice step one, the court treated the representative claims as directed to collecting, analyzing, searching, and using information—an abstract information-processing concept. The court rejected Arendi's reliance on alleged “beneficial coordination” between programs because that phrase was not a claim limitation and did not reflect a concrete technical improvement. At Alice step two, generic components and functions—analyzing text, identifying search terms, querying a data source, and using results—did not supply an inventive concept, individually or as an ordered combination. Because § 101 resolved the appeal, the Federal Circuit did not address noninfringement, claim construction, anticipation, or obviousness. § 101 § 102 § 103 claim construction infringement non-precedential § 101 § 102 § 103 claim construction infringement non-precedential § 101 non-precedential