Section 101 Examples
Example 22: Graphical User Interface For Meal Planning
This is an example provided by the U.S. Patent and Trademark Office for analyzing Section 101 patent subject matter eligibility issues. This example is taken from Appendix 2 of the July 2015 Update on Subject Matter Eligibility.
This example should be viewed in light of the introduction that was provided with it.
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Example 22: Graphical User Interface For Meal Planning
The following claim was found ineligible by the Southern District of New York, and the judgment was affirmed by the Federal Circuit in Dietgoal Innovations LLC v. Bravo Media LLC, 599 Fed. Appx. 956 (Fed. Cir. Apr. 8, 2015). The patent at issue was U.S. Patent 6,585,516. The claim is directed to an abstract idea, and the additional elements do not amount to significantly more than the abstract idea, but merely implement the idea using generic computer technology. The exemplary analysis shows how an examiner would apply the 2014 IEG analysis to the claim when making a rejection.
The invention addresses a way to solve the issue of obesity, specifically by using visuals to assist users to follow diet programs designed by health professionals for the purpose of modifying diet behavior. In particular, the invention is a computer system that “includes[s] a User Interface (UI), a Meal Database, a Food Database, Picture Menus and Meal Builder.” The UI functions to receive commands from the user and display results to the user. The Food and Meal Databases are databases of food information and preselected combinations of foods that have been compiled into a single repository. The Picture Menus display pictures of meals on the UI so the user can make a plan by mixing and matching foods to meet customized eating goals. The Meal Builder permits the user to design meals and view the impact of the food choices on customized eating goals in real time. In practice, the invention permits a user to choose meals for a particular day, as well as modify one or more of the meals to create new meals, while seeing the impact on their dietary plan. The object of the invention is to influence a person’s eating behavior.
2. A system of computerized meal planning, comprising:• a User Interface;
• a Database of food objects; and
• a Meal Builder, which displays on the User Interface meals from the Database and wherein a user can change content of said meals and view the resulting meals’ impact on customized eating goals.
Claim 2: Ineligible.
The broadest reasonable interpretation of the claim encompasses a computer system (e.g., hardware such as a processor and memory) that implements a user interface, a database, and a food data selection program. The system comprises a device or set of devices and, therefore, is directed to a machine, which is a statutory category of invention (Step 1: YES).
The claim is then analyzed to determine if the claim is directed to a judicial exception. The claim recites a system for selecting and modifying meals based upon dietary goals. In other words, the claim describes a process of meal planning. Meal planning is the organization and comparison of information to develop a guideline for eating. It is a mental process of managing behavior that could be performed in the human mind, or by a human using a pen and paper. Such a basic concept is similar to other mental processes found abstract by the courts such as comparing new and stored information and using rules to identify options in SmartGene, and obtaining and comparing intangible data in Cybersource. Therefore, claim 2 is directed to an abstract idea (Step 2A: YES).
Next, the claim is analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract idea. The only additional limitations in the claim relate to computerization of meal planning with an interface, a database of food objects, and a “meal builder,” which is a computer program that allows selection and comparison of food data. The meal builder would require a processor and memory in order to perform basic computer functions of accepting user input, retrieving information from a database, manipulating that information and displaying the results. These components are not explicitly recited and therefore must be construed at the highest level of generality. The interface is also recited at a high level of generality with the only required function of displaying, which is a well‐known routine function of interfaces. Further, the database performs only its basic function of storing information, which is common to all databases. Thus, the recited generic computer components perform no more than their basic computer functions. These additional elements are well‐understood, routine and conventional limitations that amount to mere instructions to implement the abstract idea of meal planning on a computer. Taking these computer limitations as an ordered combination adds nothing that is not already present when the elements are taken individually. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B: NO). The claim is not patent eligible.
A rejection of this claim should identify the abstract idea of selecting meals for a customized eating goal, which is similar to concepts of obtaining and comparing data that were found to be abstract by the courts. The rejection should also identify the additional elements and explain the reasons why they amount to no more than merely implementing the idea of meal planning using generic computer components.