Judge Paul A. Engelmayer of the Southern District of New York granted summary judgment to Klarquist client Bravo Media, LLC (a division of NBC Universal Media LLC) that U.S. Patent No. 6,585,516 (the ‘516 patent) was invalid under 35 USC § 101 for failing to claim patent-eligible subject matter. The ‘516 patent was generally directed to a system and method for using a computer to plan meals to meet one’s nutritional goals. Applying the Supreme Court’s decisions under § 101, including Alice Corp. Pty. Ltd. v. CLS Bank Int’l, Judge Engelmayer held on July 8, 2014, that the ‘516 patent claimed an abstract concept of meal planning on a general purpose computer. Judge Engelmayer also subsequently granted summary judgment to Klarquist client Time Inc. in a separate case on the basis of collateral estoppel. The Federal Circuit affirmed the summary judgment of invalidity on April 10, 2015.
The DietGoal cases against Klarquist’s clients traveled a winding road to victory. DietGoal filed its cases in the Eastern District of Texas. Klarquist filed transfer motions on behalf of its New York-based clients, but the Texas court instead sent the cases to Virginia. The Virginia court then granted Klarquist’s motions to re-transfer the cases to New York, where summary judgment motions were filed and granted.