Overview
In an opinion issued today, Judge Engelmayer granted Bravo Media's motion for summary judgment against DietGoal innovations, the holder of a patent for a "computerized method and system for diet-related behavior analysis, training, and planning." As Judge Engelmayer explained:
[T]he claims of the ’516 Patent, viewed as a whole, recite nothing more than “the concept of [meal planning] as performed by a generic computer.” Alice, 573 U.S. at ___ (slip op., at 15). The Patent specifies that the user can choose preset meals and food items from the Databases, see those meals displayed using the Picture Menus, and change those meals on the Meal Builder, as well as visualize the impact of those changes. These steps, however, are insufficient to transform the abstract idea of meal planning into a patentable process. The addition of a computer to perform calculations, retrieve data, and visually display images is nothing more than “post-solution activity” that cannot render the process patentable. In sum, the addition of the computer here is not “‘sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the [ineligible concept] itself.’”