The reason people say eating late at night is bad isn't because it's bad to eat at say... 'night'. It's bad to eat before 'bed' is the answer. This is because your metabolism slows down and the food sits in your stomach longer, it uses less of that energy while you're sleeping and the extra energy becomes not unlike calories not used during the daily routine. Now say, if you work the night shift and you want your evening lunch by all means, go ahead. If you don't go to sleep until 6:00 am there shouldn't be any issue with eating at 3:00am. Just realize that if you're laying down within two hours you might have some extra calories that are being devoured at a much slower rate.