Case Number: 1:13–cv-08391–PAE
Judge Engelmayer found claims of DietGoal’s U.S. Patent No. 6,858,516 (“Method and system for computerized visual behavior analysis, training, and planning”) invalid under § 101, and so he granted Bravo’s motion for summary judgment of invalidity. He declined to rule on summary judgment of non-infringement.
One claim at issue reads as follows:
1. A system of computerized meal planning, comprising:
a User Interface;
a Database of food objects organizable into meals; and
at least one Picture Menus, which displays on the User Interface meals from the
Database that a user can select from to meet customized eating goal.
The court said that the claims were sufficiently straightforward such that claim construction was not necessary.
Turning to the first prong of the Mayo/Alice framework, Judge Engelmayer found that the claims were directed to a patent-ineligible concept (i.e., laws of nature, natural phenomena, and abstract ideas). He said that the claim’s concept is “computerized meal planning,” and that upholding the patent would thus “effectively grant a monopoly over an abstract idea.” Further, apparently deciding that the un-construed claims “could be performed in the human mind, or by a human using a pen and paper,” the court reiterated that the claims cover only an abstract idea.
Turning...
