Author Archive

Encrypting/decrypting audio data with reduced latency: technical

In this decision, the European Patent Office did not grant a patent on a method of encrypting/decrypting audio data without adding substantial latency to the audio processing. Here are the practical takeaways of the decision T 2327/17 (Authenticated encryption of audio data/BOSCH) of 21.2.2020 of Technical Board of Appeal 3.5.05:

Key takeaways

Increasing the cryptographic security of an audio data stream is a technical problem.

The invention

This European patent application generally relates to the encryption and decryption of audio data. According to the background explained in the application, digital audio is typically generated on a certain audio sample frequency, and it is common to collect a larger block of data and protect this data block via encryption. After encryption, the data is processed for the second time to add authenticity (integrity) protection, which is essential for avoiding unauthorized manipulation of data.

However, in scenarios such as live music systems, ultra low latency is required to avoid losing the rhythm for the musician. Since any processing, e.g. analog digital conversion, audio processing, transmission of data, will add latency to the audio data, it is important that encryption and decryption latency are as low as possible, e.g. < 0,05 ms.

Fig. 1 of EP 2 553 862
Fig. 1 of EP 2 553 862

Here is how the invention is defined in claim 1:

  • Claim 1 (main request)

Is it technical?

The board of appeal started its assessment from a prior art document which already disclosed the use of AES in Cipher feedback mode to encrypt/decrypt audio data. The board also took it as common general knowledge that in an encryption/decryption scheme in cipher feedback mode, the need for additional synchronisation is removed and that without knowing an initialisation vector from the encryption it takes the number of bits from a cipher-block before the correct data can be decrypted.

Claim 1 therefore differed from the closest prior art in that it comprises the further step of detecting whether a CMAC authenticity check is successful from a single audio sample and that the method is performed on a sample by sample basis with a latency less than 1 mys.

First of all, it was questionable whether the feature “with a latency less than 1 mys” in claim 1 was clear, or amounted merely to a result to be achieved:

With respect to the feature “with a latency less than 1 mys”, the appellant argued that this feature was implied by the choice of a length of 24 bits for the audio sample which resulted in a CMAC authenticity check in less than 1 mys. The length of an audio sample being however not defined in claim 1, the board agrees with the decision under appeal (see point 7.2.8) that defining that the latency is less than 1 mys amounts to merely define a result to be achieved.

Secondly, also the feature “the method is performed on a sample by sample basis” had been objected as vague and unclear in the first instance decision. Here is what the board said:

In respect of interpretation of the vague and broad feature “the method is performed on a sample by sample basis”, the appellant argued that it should be interpreted as meaning that not only the CMAC authenticity check but also the AES decryption in Cipher feedback mode were performed on a sample by sample basis. In its view, obtaining a plain 24-bits audio sample, as shown by reference sign 126 in Figure 2 and described on page 5, lines 22 to 24, was an evidence that the decryption was performed on a sample by sample basis. However, the board notes that the decryption of a 24-bits audio sample at stage n + 1 depends on the decryption of the previous sample at stage n, as shown in Figure 2 and as implied by the use of a Cipher feedback mode. The board thus agrees with the decision under appeal (see point 7) that the decryption in AES Cipher feedback mode cannot be interpreted as being performed on a sample by sample basis so that the feature “the method is performed on a sample by sample basis” has to be interpreted as applying CMAC authenticity check on a sample by sample basis.

Turning to inventive step, the board first identified the effect achieved by the features that distinguished the invention from the prior art:

The technical effect of the above-mentioned distinguishing features is that invalid audio samples are detected without having to wait for the large number of audio samples, such as the whole audio data, to be received and decrypted. The objective technical problem can thus be formulated as how to increase the cryptographic security of the audio data stream.

The question was thus whether it was obvious to come up with the invention as claimed to solve the objective technical problem:

The person skilled in cryptography, trying to improve the reliability of a received encrypted audio stream, would obviously consider to use an authentication scheme to add security to the encryption scheme. The skilled person would consider D7 which discloses to split a Voice over IP stream, i.e. an audio stream, into short packets, or chunks, to encrypt them using a conventional encryption scheme, to accompany each chunk with a Message Authentication Code MAC, and to compare the transmitted MAC with a recalculated MAC at reception (see the paragraph bridging pages 274 and 275). It was moreover well known at the priority date of the present application to use block-cipher-based MAC, i.e. CMAC, as MAC. By applying the teaching of D7 to the disclosure of D5 the skilled person would thus arrive at the subject-matter of claim 1 without the exercise of inventive skills.

Therefore, claim 1 was found to lack an inventive step, and the appeal was dismissed.

More information

You can read the whole decision here: T 2327/17 (Authenticated encryption of audio data/BOSCH) of 21.2.2020

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Gesture-based information table transposition: non-technical

In this decision, the European Patent Office did not grant a patent on the idea of allowing a user to specify, via display gestures, two possible ways of transposing a displayed information table. Here are the practical takeaways of the decision T 1505/17 (Transposition gestures/HUAWEI TECHNOLOGIES) of 17.2.2020 of Technical Board of Appeal 3.5.07:

Key takeaways

Allowing a user to specify one of two possible table transpositions is non-technical, reflecting the user’s subjective wish to choose how to transform the table. Indeed, transposing a displayed table, e.g. in the context of a word processor and for editorial reasons, is itself non-technical.

Whether or not a particular input gesture or other kind of input mechanism is intuitive to the user is normally a subjective and not a technical matter.

The invention

This European patent application generally relates to allowing a user to transpose a displayed table such that the columns become rows and the rows become columns. The description relates mainly to mirroring the table in its main diagonal, i.e. from the top-left corner to the bottom-right corner. An example is shown in Fig. 1A (original table) and Fig. 1B (transposed table):

Figs. 1A and 1B of EP 2 645 271
Figs. 1A and 1B of EP 2 645 271

Here is how the invention is defined in claim 1:

  • Claim 1 (main request)

Claim 1 is directed to a “table graphics management method”. The method first displays a table which has multiple rows and columns. When a “control track for the table” input by an input device is detected, a “moving direction” of the detected control track is determined. In view of dependent claim 3, the “control track” may be a “touch track” entered via a touch input apparatus. Therefore, the board understood the step “detecting a control track” as meaning that an input command in the form of a gesture is detected.

The claim refers only to a single row and column and to “transposing” information from the frames of the row into the frames of the column and vice versa. However, the phrase “so as to acquire a transposed table” and the examples given in the description make it clear that the table as a whole is transposed, resulting in the rows of the table being converted into columns and the columns into rows.

Claim 1 does not specify what is meant by transposing “along the moving direction of the control track”. Based on the disclosure in the application, the user can specify a transposition that transposes corner frame 11 in Figure 1A into corner frame 14 in Figure 1B by inputting a gesture that starts in frame 11 and moves in the general direction of frame 13 (of Figure 1A), i.e. perpendicular to the diagonal in which the table is mirrored. However, the board took the view that the expression “transposing along the moving direction” could also be understood as referring to the transposition that mirrors the table in the diagonal indicated by the “moving direction”. At the oral proceedings, the appellant agreed that both interpretations were possible.

Is it technical?

According to the board, claim 1 differed from the closest prior art in that the control input is a “control track” instead of a button click and in that the table is transposed “along the moving direction of the control track”, allowing the user to specify one of two possible transpositions.

First of all, the board assessed whether the concept of two possible types of transpositions was a technical feature:

In the Board’s judgment, the idea of allowing the user to specify one of the two possible table transpositions is non-technical, reflecting the user’s subjective wish to choose how to transform the table. Indeed, transposing a displayed table, for example in the context of a word processor and for editorial reasons, is itself non-technical. This non-technical idea may thus be included in the formulation of the objective technical problem.

Hence, the objective technical problem to be solved may be formulated as modifying the method of document D1 to allow the user to input commands for the two possible table transpositions.

Accordingly, what had to be assessed was whether enabling two different gestures to solve the problem was non-obvious:

In view of the prevalence of smartphones and tablets at the filing date of the present application, i.e. in April 2012, inputting user interactions by means of gestures, e.g. gestures made by moving a mouse or by moving a stylus or finger over a touch pad or touch screen along a “control track”, was well known in the art. To implement two different control options, one would have had to provide two distinguishable gestures. Distinguishing the two gestures on the basis of their control track’s “moving direction” would have been an obvious possibility, just like a scroll-down gesture was commonly distinguished from a scroll-up gesture by the gesture’s direction.

[…] The skilled person would thus have arrived at the claimed subject-matter without the exercise of inventive skill.

One argument of the appellant was that the use of gestures had several advantages, such as replacing a multitude of clicks and requiring fewer icons to be displayed. The problem to be solved had to be formulated as “modifying the method of document D1 for increasing usability on smaller displays and/or touch screens”. However, the board held that these advantages were among the known and expected advantages of the use of gestures (and indeed are not mentioned in the application as filed) and therefore cannot support an inventive step.

The appellant also argued that the claimed gestures were particularly intuitive. However, also this did not convince the board:

Given the lack of precision in the definition of the claimed gestures (see point 3.5.1 above), the Board is not convinced that the claim encompasses only the use of “intuitive” gestures. In any event, whether or not a particular input gesture or other kind of input mechanism is intuitive to the user is normally a subjective and not a technical matter.

In the end, claim 1 was found to lack an inventive step, and the appeal was dismissed.

More information

You can read the whole decision here: T 1505/17 (Transposition gestures/HUAWEI TECHNOLOGIES)

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Mapping natural language text input to elements of a social-graph database: non-technical

In this decision, the European Patent Office did not grant a patent on a system for structured queries in social networks, particularly for mapping natural language text input to elements of a social-graph database. Here are the practical takeaways of the decision T 1089/17 (Ambiguous queries on online social networks/FACEBOOK) of 7.2.2020 of Technical Board of Appeal 3.5.07:

Key takeaways

Defining a natural language query is per se not a technical task, but lies in a non-technical field.

The invention

This European patent application, filed by Facebook, Inc., generally relates to social graphs and performing searches for objects within a social-networking environment.

The invention proposes a social-networking system that may, in response to a text query received from a user, generate structured queries that include references to particular social-graph elements. By providing suggested structured queries in response to a user’s text query, the social-networking system may provide a way for users of an online social network to search for elements represented in a social graph based on their social-graph attributes and their relation to various social-graph elements.

For example, when a user enters the ambiguous search term “facebook” as part of the search query “people who like facebook” (a shown in the figure below), the online social network may propose several matching elements of the social graph to the user for selection. If the user then selects one of the proposed matching elements (for example, “Facebook”), the system proposes a set of queries related to the selected graph element (for example, “People who work for Facebook”, “People who like Facebook and Stanford”), from which the user can select one to be performed.

Fig. 4C of EP 2 750 056
Fig. 4C of EP 2 750 056

Here is how the invention is defined in claim 1:

  • Claim 1 (main request)

Is it technical?

Already in the European search opinion, the application was considered to be directed “at a cognitive problem”. In essence, the claim elements related to the social graph were found to be “purely social-administrative”, and the elements related to the query processing were considered to have “a purely cognitive character”. Following the EPO’s appproach for mixed-type inventions, the examiner held that the closest prior art was a general-purpose computer system, and that implementing the non-technical method on such notoriously known hardware was obvious. The examining division essentially maintained this position throughout the prosecution procedure, so that the application was refused for lack of inventive step in first instance.

On appeal, the applicant argued that the operation and function of the claimed search engine may be considered to lie in a technical field. The board agreed as far as none of the cited documents was considered to disclose a search process which maps natural language text input to elements of a social-graph database in the context of a social network. The board therefore took document D5 (a patent application by Facebook itself) as the starting point for assessing inventive step.

The board found that the invention as claimed differed from D5 by “generating a second set of structured queries, each structured query of the second set of structured queries comprising a reference to the selected second node or selected edge”. Here is how the board interpreted these features:

The distinguishing features have the effect of generating a set of exemplary queries regarding a selected element of the social graph. In this respect, the Board observes that the application discloses ranking the structured queries based on advertising sponsorship (description, paragraph [0075]), which seems to suggest that the generated queries may serve a non-technical purpose and result from business considerations.

The claimed generation of queries according to features 8 and 8.1 does not contribute to a “further” technical effect. In particular, the Board does not agree that the human-machine interaction is improved, as no interaction between the user and the system after the disambiguation of the entered data is claimed. The distinguishing features do not involve any further interaction or the display of the generated second set of structured queries to the user.

Moreover, the Board considers that defining a natural language query is per se not a technical task, but lies in a non-technical field. As the claim is entirely silent regarding the user interface for entering search queries, the Board is not convinced that the claimed method solves a technical problem in the area of user interfaces.

The applicant also argued that the fact that claimed subject-matter had some relation to “semantic” aspects did not inevitably imply that it was of non-technical character. Non-technical character could only be affirmed if absolutely no further technical considerations, for example related to the database/search engine and their structure and/or function, were involved. But also this argument did not persuade the board:

The Board is not convinced that the distinguishing features involve any “further technical considerations” (see opinion G 3/08, OJ EPO 2011, 10, Reasons 13.5.1), as the generation of the second set of queries is based on non-technical considerations regarding the desired query semantics in the context of the social graph. The Board observes that the social graph, which is known from document D5, constitutes social data not serving a technical purpose, and the distinguishing features do not define whether or how the social graph as a data structure is used to generate the second set of structured queries.

Lastly, the applicant argued that the generated search term related to the underlying graph structure of the database, so that the invention takes the technical structure of the underlying database and search engine into account, which makes a technical contribution. But the board also did not follow this argument:

However, the social graph is already known from document D5, and the distinguishing features 8 and 8.1 define the generation of the second set of structured queries only in terms of non-technical semantic aspects. Consequently, the Board considers that features 8 and 8.1 are not about exercising technical control over the functioning of the search engine in the sense of decision T 2230/10. Hence, the Board is not persuaded by the appellant’s arguments.

As a result, the board held that the distinguishing features do not contribute to the solution of a technical problem and cannot be considered for the assessment of inventive step. Claim 1 was found to lack an inventive step.

More information

You can read the whole decision here: T 1089/17 (Ambiguous queries on online social networks/FACEBOOK)

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Object detection in an augmented reality image: insufficiently disclosed

In this decision, the European Patent Office refused an application in the field of augmented reality, because the claimed object detection technique was not sufficiently disclosed. Here are the practical takeaways of the decision T 0677/17 (Augmented reality, detecting position of apparatus / Sony) of 13.2.2020 of Technical Board of Appeal 3.5.05:

Key takeaways

A European patent application has to disclose the invention so clearly and completely that it can be carried out by a person skilled in the art over essentially the whole scope claimed.

The invention

This European patent application generally relates to apparatuses and a system for presenting an image comprising real space parts and superimposed virtual parts to two users. The positions of the apparatuses used by the users are detected and taken into account.

Fig. 2 of EP 2 352 117
Fig. 2 of EP 2 352 117

Here is how the invention is defined in claim 1:

  • Claim 1 (main request)

Is it patentable?

The board had doubts whether the patent application disclosed the invention in a manner sufficiently clear and complete for it to be carried out by a person skilled in the art. The discussion revolved around the feature in claim 1 of “an other terminal detection unit (158) for detecting the image of the other apparatus (20) included in the real space image and for specifying a spatial coordinate of the other apparatus (20) in the spatial coordinate system based on the real space image”.

According to the board, this unit carries out two functions:

  • (a) detecting the image of the other apparatus included in the real space image; and
  • (b) specifying a spatial coordinate of the other apparatus in the spatial coordinate system based on the real space image.

First of all, the board tried to interpret the technical meaning of these features based on the description:

The real space image referred to is, for example, “a landscape captured by an imaging apparatus” (paragraph 44). In particular, a two-dimensional digital image, as taken by a digital camera, is covered by the claim’s wording.

The description, in paragraph 55, sets out that “[t]he image of the other terminal included in the real space image, for example, can be detected using a well-known image processing means for performing background difference and the like”. Similar wording is repeated in paragraph 82. These passages are the only explanation in the description relating to function (a).

The application does not contain any further explanation of the “background difference” image processing technique. In the field of image processing “background difference” is mostly used for detecting a moving object in a movie sequence. However, the “other terminal detection unit” as claimed does not have a movie sequence at its disposal, but only a real space image. Moreover, the detection of the image of an apparatus included in a real space image presupposes that the detecting unit possesses information about properties of the apparatus to be detected, e.g. size, form, colour, etc., or alternatively about properties of the background included in the real space image. In the board’s view, claim 1 does not specify or limit the properties of the other apparatus or of the background.

As to feature (b), the board notes that clearly the spatial coordinates of the other apparatus can only be specified once the other apparatus has been detected. In this regard, paragraph 55 contains the following explanation:

“the position of the other terminal in the spatial coordinate system, for example, can be specified using a position detection method disclosed in Japanese Unexamined Patent Application Publication No 2006-209334 and the like”.

According to the abstract, this Japanese patent application pertains to the detection of the position of a human person in a two-dimensional image. Paragraph 61 of the description of this publication suggests that another animal or another moving body can be detected too; however no corresponding details are provided. Hence, this published application does not provide an enabling disclosure for feature (a) or (b) over essentially the whole scope claimed.

Also the common general knowledge did not lead to another result:

The board is not aware of any common general knowledge which would enable the skilled person to put into practice the features referred to in section 1.1, in particular in view of the very broad wording “image of the other apparatus”.

At the oral proceedings, the appellant had argued that the line of sight to the other apparatus was known and only the distance from it had to be detected in order to specify the spatial coordinates of the other apparatus. But the board did not follow this argument either:

The board does not accept this argument. As set out above, detecting the image of a not further specified other apparatus in a two-dimensional image taken by one camera is not sufficiently disclosed. Clearly, the image of the other apparatus has to be detected first, before a line of sight can be established.

In the end, the board concluded that the application does not disclose the claimed invention in a sufficiently clear and complete manner, and dismissed the appeal.

More information

You can read the whole decision here: T 0677/17 (Augmented reality, detecting position of apparatus / Sony)

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Multidimensional data structure with a hierarchy of levels for each dimension: technical

In this decision, the European Patent Office considered a particular multidimensional data structure with a hierarchy of levels for each dimension to provide a technical effect. Here are the practical takeaways of the decision T 1159/15 of 6.4.2020 of Technical Board of Appeal 3.4.03:

Key takeaways

Defining a particular multidimensional data structure with a hierarchy of levels for each dimension, and instructions on how stored data are to be aggregated up to higher levels of each dimension provides a “further technical effect” which affects the storage space used and the speed of processing

The invention

This European patent application generally relates to mathematical models that are created based on stored information, variables and assumptions (conditions). The variables and assumptions are modified and several candidate models are generated and evaluated. Based on these evaluations, one of these candidate models is selected as the final model and is used for forecasting purposes.

The application mentions models related to sales of a product as one example. Based on various variables (e. g. price, geographical distribution, advertisement cost) and assumptions (e. g. higher prices decrease sales or increased advertisement costs increase sales) models attempting to estimate future sales are generated and used in order to create a business plan.

Fig. 1 of EP 2 273 431
Fig. 1 of EP 2 273 431

Here is how the invention is defined in claim 1:

  • Claim 1 (sole request)

Is it technical?

The examining division had considered that claim 1 comprised technical and non-technical features, and that the only technical feature of the claim was a general purpose computer (as implied by the feature “a model evaluation module (204) executable by a computer…”). All the other features of the claim related to a business method as such.

According to the examining division, such a general purpose computer was so well-known before the priority date of the application that it did not require written evidence. Thus, No prior art search was carried out during the first instance procedure.

The appellant contested this decision and argued that at least the claimed multidimensional data storage system storing information for the models which uses a meta data layer and a data layer to store the information were technical features. According to the appellant, these features defined a particular way of storing data in the data storage of the claimed system which was not the “notorious” way data would be stored in a general purpose computer. Hence, a prior art search should have been carried out.

Here is what the board of appeal decided:

The defined data storage is multidimensional and comprises a meta data layer and a data layer to store the information. Variables are stored in the data layer. These variables have dimensions (attributes) organised in a hierarchy. The hierarchy may include sub-attributes or levels for each dimension. For example, one dimension may be geography and the levels in the hierarchy may be country, region, city and zip code (see paragraph [0015] of the application).

The meta data layer stores, among others, aggregation rules for the stored data. The aggregation rules describe how to aggregate up from a lower level in a hierarchy to a higher level and what transformation to apply for each level (see column 9, lines 14 to 25 of the application as published).

This configuration enables the system to respond to multidimensional queries across different levels in the hierarchies (see paragraph [0039] of the application).

Moreover, as defined in claim 1, the data storage system stores data at the lowest level of each dimension and uses the aggregation rules to determine how data are to be aggregated up to hierarchically higher levels in the dimension (see also column 9, lines 25 to 33 and paragraph [0058] of the application).

In the board’s view, the defined data storage contains two types of data. Firstly, data encoding cognitive content, such as information related to variables, assumptions etc. These data are used in the generation of the models. Secondly, the aggregation rules, which are not related to any cognitive content but are instructions related to the operation of the system when responding to queries. These data could thus be characterised as “functional data” (see also T 1194/97, OJ EPO 2000, 575, Headnote II and Reasons 3.3 to 3.5; T 425/03, Reasons 6.2 and 6.3).

The features of claim 1 identified above define thus a particular multidimensional data structure with a hierarchy of levels for each dimension, in which data are stored at the lowest level of each dimension. Moreover, the data structure stores instructions on how the stored data are to be aggregated up to higher levels of each dimension (see also paragraphs [0042] and [0043] of the application).

In the board’s view, these features provide for a technical effect that goes beyond the “normal interactions” within a computer executing a business method, because they define a particular way in which data are stored, retrieved and processed, which affects the storage space used and the speed of processing.

This would be a “further technical effect” so that these features are to be regarded as technical features and not as part of the non-technical (business) features of the claim.

The board points out that the assessment of the technical effect(s) obtained by the identified technical features, i. e. whether there is less storage space used or the query processing speed is higher, involves a comparison with the state of art and belongs, hence, to the discussion about inventive step. It is established case law and practice that assessment of the technical character of the claimed-subject matter is to be carried out without any consideration of the state of the art.

It follows from the above that in the assessment of inventive step of the claimed subject-matter, the identified technical features should not be included in the non-technical aim that is given to the skilled person for implementation.

Moreover, the board is also of the opinion that these technical features define a particular way of storing, retrieving and processing data, which does not fall under the generic definition of a general purpose computer with the corresponding data storage. In the board’s view these features cannot be considered as being notoriously well-known technical features for which no documentary prior art evidence is necessary.

Therefore, the case was remitted back to the examining division for further prosecution, including carrying out a prior art search.

More information

You can read the whole decision here: T 1159/15

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Email filtering based on number of inappropriate URLs: non-technical

In this decision, the European Patent Office refused to grant a software patent on the concept of filtering and blocking emails if they contain a certain number of inappropriate URLs. Here are the practical takeaways of the decision T 2363/16 (URL based email filtering/MICROSOFT TECHNOLOGY LICENSING) of 6.12.2019 of Technical Board of Appeal 3.5.07:

Key takeaways

Classification of messages as a function of their content is not technical per se (confirmation of T 22/12)

The invention

This European patent application generally relates to the filtering of electronic communications and websites based on the appropriateness of their content. The purpose is to block access to undesirable content, e.g. unsolicited commercial offers or content inappropriate for children.

The invention involves parsing a received email to identify URLs (uniform resource locators) within the email and looking up a rating for each of the identified URLs in a database. If a sufficient number, rating or percentage of the URLs are categorised as “inappropriate”, the electronic communication may be blocked.

The ratings are obtained from a database of categorised URLs, which contains URLs, representing public web pages, and category labels indicating membership in “inappropriate” categories, including pornography, hate speech, mature content and drugs. The database contents are served up online through custom lookup servers called category name service (CNS) servers.

Fig. 1 of EP 1 510 945
Fig. 1 of EP 1 510 945

Here is how the invention is defined in claim 1:

  • Claim 1 (main request)

Is it technical?

The board started its inventive-step analysis from a document describing the anti-spam and web filtering products called OrangeBox Mail and OrangeBox Web Home. This document disclosed an email filtering method including steps of receiving and parsing an email message, identifying URLs in the parsed email message, transmitting the URLs to a CNS and receiving a rating as defined in claim 1.

The difference between the invention and the prior art method was thus in the criteria that are taken into account to decide whether to inhibit access to an email. The prior art disclosed checking URLs in emails against a URL filtering database but not the specific check specified in claim 1.

The board therefore found that claim 1 differed from the prior art in that the policy establishes that an email is to be blocked if the “number of inappropriate URLs exceeds a threshold greater than zero”.

Here is how the board summarized the appellant’s arguments in favor of a non-obvious technical contribution of this difference:

In the grounds of appeal, the appellant argued that, contrary to the contested decision’s reasoning, the invention did not apply a certain (non-technical) standard of morality but instead provided a technical teaching of how to make use of an appropriate/inappropriate rating received from a server in an improved and non-obvious way. What would have been obvious from document D11 would be to block an email if a URL link contained in the email were listed in the URL filtering database. The invention went beyond this obvious solution by determining whether the number of inappropriate URLs exceeded a threshold greater than zero.

At the oral proceedings, the appellant further argued that the distinguishing feature did not relate to a non-technical user requirement regarding how much inappropriate content was tolerated, it rather taught how to perform the appropriateness test in a technically advantageous manner. The users did not care about how the determination was made, they merely wanted to be protected. The decision of how to perform the content-appropriateness test was not made by an administrator but by the technically skilled person. The test of distinguishing feature (i) had the technical advantage of being surprisingly simple and was inventive. At the priority date 16 years ago, such an improvement would not have been obvious.

However, the board took another point of view:

However, classification of messages as a function of their content is not technical per se (T 22/12 of 16 November 2015, reasons 2.2). In the present case, the classification criteria regarding which emails should be blocked are determined by the user of the system based on non-technical considerations regarding which emails the user does not want to receive. Distinguishing feature (i) therefore merely reflects a non-technical criterion or policy according to which an email is acceptable if it refers to a number of inappropriate web pages that does not exceed a threshold greater than zero. Implementing this policy by determining whether the number of inappropriate URLs exceeds such a threshold, is an obvious way to implement the non-technical criterion in the method of document D11, which already uses URLs in a similar way.

As a result, the board decided that claim 1 lacked an inventive step and dismissed the appeal.

More information

You can read the whole decision here: T 2363/16 (URL based email filtering/MICROSOFT TECHNOLOGY LICENSING) of 6.12.2019

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Sorting review information in priority order: non-technical

In this decision, the European Patent Office refused to grant a software patent on the concept of sorting review information in priority order to reduce the time and effort for a user to find desired review information. Here are the practical takeaways of the decision T 0886/17 (Displaying review information in priority order/Rakuten) of 6.3.2020 of Technical Board of Appeal 3.5.07:

Key takeaways

Sorting or grouping data in a particular manner on the display is a matter of the presentation of information, which as such is non-technical.

Not every physical change qualifies as a technical effect. A physical change caused by non-technical features is to be regarded as a technical effect for the purpose of assessing inventive step if the non-technical features are based on technical considerations aimed at controlling that physical change.

When assessing the presence of a credible technical effect in inventions involving presentations of information, a distinction has to be made between subjective psychological factors and objective physiological factors.

It is standard practice in user interface design to minimise the number of interactions.

The invention

This European patent application generally relates to providing review information about “transaction targets” such as products or accommodations. The system receives a search condition input by a user (e.g search words), searches transaction targets matching the search condition, and displays review information regarding the transaction targets in a predetermined display order. The purpose of the invention was to reduce time and effort necessary for a user to find desired review information.

Fig. 6A of EP 2 725 502
Fig. 6A of EP 2 725 502

Here is how the invention is defined in claim 1:

  • Claim 1 (main request)

Is it technical?

The examining division had decided that claim 1 then on file constituted a straightforward technical implementation of a non-technical administrative and business-related scheme in a notorious electronic data processing system.

On appeal, the board started its patentability analysis from a notoriously known information retrieval system:

At the date of priority of the present application, web-based information retrieval systems which gave the users the possibility of reviewing or rating articles of interest and viewing such information as part of the search results were notoriously known. The application acknowledges in paragraph [0002] that such systems were known.

Such a notorious information retrieval system, which was the starting point for assessing inventive step in the Board’s preliminary opinion, includes searching means, acquiring means and controlling means similar to those defined in claim 1.

The board identified three differentiating features in the invention according to claim 1:

  • (a) the transaction targets are stored in a first computer database and the review information is stored in a second computer database distinct from the first;
  • (b) the apparatus includes determining means for determining a priority order of the pieces of review information of each transaction target which satisfies the search condition, the priority order being determined “according to a correspondence between the search condition and the pieces of review information”; and
  • (c) a list of pieces of review information comprising at least one piece of review information associated with the identification information of each target is generated and displayed in the determined priority order.

The first difference was found to be just a minor implementation detail not helpful for the patentability of the invention:

Distinguishing feature (a) is a minor obvious implementation detail. It is common practice to distribute data across different databases. In addition, the Board is not convinced that feature (a) interacts with features (b) and (c) in such a way as to produce a synergistic effect. This was not contested by the appellant.

More interesting were the other two differentiating features, which relates to sorting the pieces of review information and displaying them in the sort order. These features were found to have the effect of changing the way the pieces of review information are presented to the user. One of the central questions of this appeal was thus whether this effect was a technical one:

Computer programs and presentations of information as such are excluded from patentability under Article 52(2)(c) and (d) and (3) EPC. Furthermore, sorting or grouping data in a particular manner on the display is a matter of the presentation of information, which as such is non-technical (T 2045/10 of 28 April 2016, Reasons 5.6.2). It therefore has to be assessed whether features (b) and (c) interact with technical features of the invention to solve a technical problem bringing about a technical effect (T 2045/10, Reasons 5.6.2 to 5.6.4; T 1442/16 of 30 August 2019, Reasons 1.4; T 697/17 of 17 October 2019, Reasons 4.2 and 5.2.2).

The appellant had argued that an important distinguishing aspect of the invention was using the same search condition used to search the transaction targets to determine the priority order, and that this produced three technical effects:

  1. The first effect was a reduction of the load on the information retrieval apparatus, which was clearly not a cognitive effect. By performing the search and ordering together, fewer processing steps were necessary.
  2. The second effect, improved ergonomics, was achieved by requiring the user to enter the search condition only once, which resulted in fewer mouse clicks or key press operations. Since this related to physical movement, it was technical. In the prior art, the search results were first displayed and then the user had to select one of the displayed search results and scroll down to the “reviews” section. Typically, the user had then to click “see all reviews” in order to go to a page showing a number of reviews. This page had options to order the reviews. The user had to enter the search term again to sort the review information.
  3. The third effect was that the computer was “controlled to the memory location” of the pieces of review information which, in accordance with decision T 1351/04 of 18 April 2007, was a technical effect.

Here is what the board made of these arguments:

Even though the case law generally recognises a technical contribution by non-technical features if they are causally linked to a technical effect, not every physical change qualifies as a technical effect. A physical change caused by non-technical features is to be regarded as a technical effect for the purpose of assessing inventive step if the non-technical features are based on technical considerations aimed at controlling that physical change (T 697/17, Reasons 5.2.2; T 2230/10 of 3 July 2015, Reasons 3.7). The physical change has to be purposively used in the solution of a technical problem (T 258/97 of 8 February 2002, Reasons 6).

In the present case, distinguishing features (b) and (c) are not purposively directed to reducing the processing load or to directing the computer to a memory location. They are not based on technical considerations of how to achieve these effects, but rather on non-technical considerations regarding the information of interest to the user. In particular, the conclusions of T 1351/04 do not apply here. Unlike in T 1351/04, the present invention does not use an index or similar “management information” providing a path to the desired data, and the Board cannot see any technical considerations regarding directing the computer to a memory location.

The Board agrees with the appellant that teachings from case law should not be dismissed because the specific means used to achieve a technical effect there are not identical to those used in the present case, but notes that the question of which specific means are used to achieve an alleged technical effect, and thus whether they are comparable to those of the case law, is pertinent because features can only make a technical contribution if they are based on technical considerations (see also T 697/17, Reasons 4.2, 5.2.2, 5.2.3).

The Board is therefore not convinced that distinguishing features (b) and (c) can be considered to make a technical contribution by virtue of the first and third alleged technical effects.

With regard to the second alleged technical effect, the appellant cited decision T 1375/11 of 31 March 2016, which affirms that it is well established by the Boards of Appeal that improving ergonomics is technical (Reasons 4.4). In that decision, the invention was considered to solve the problem of avoiding the fatigue caused by the repetitive movements of the user’s eyes and head necessary to follow the displayed game, which were physiological aspects (Reasons 4.2 to 4.7). However, in the present case, there are no repetitive movements of the head and eyes or other physiological factors.

When assessing the presence of a credible technical effect in inventions involving presentations of information, a distinction has to be made between subjective psychological factors and objective physiological factors (T 1375/11, Reasons 4.6; T 1442/16, Reasons 1.8). Furthermore, it is established jurisprudence of the Boards of Appeal that “lowering the cognitive burden of a user” per se cannot as a rule be considered a technical effect (T 1802/13 of 10 November 2016, Reasons 2.1.7; T 1741/08 of 2 August 2012, Reasons 2.1.6).

In the present case, the allegedly achieved reduction in user interaction steps depends on cognitive aspects, and the Board is not convinced that the use of the search condition for determining the priority order is primarily based on technical considerations regarding ergonomics. If that order were not relevant for the user, then sorting the information according to that order would potentially result in more user interaction steps. As mentioned by the appellant, the priority order is chosen so that review information in which a user is very interested is preferentially displayed among pieces of review information of transaction targets. In that way, the user can grasp information more easily or find information with less effort. However, as argued in the decision under appeal, those are effects that remain at the cognitive level and are subjective. Therefore, the priority order and the presentation aspects of features (b) and (c) do not have to be considered in the assessment of inventive step. If a technical problem is solved, these aspects can be included in the formulation of the technical problem (T 641/00, OJ EPO 2003, 352, Reasons 7).

If it is assumed, in line with the appellant’s argument, that the invention contributes to the technical effect of facilitating user interactions, then features (b) and (c) constitute an advantageous solution to the problem of modifying the notorious information retrieval system to display the pieces of review information according to a priority order determined by the “correspondence between the search condition and the pieces of review information”.

However, it is standard practice in user interface design to minimise the number of interactions. Knowing that the priority order is based on the search condition, it is thus obvious for the skilled person to reuse the search condition to generate and immediately display the ordered list instead of requiring further input from the user. Modifying the notorious information retrieval system to determine a specific priority order and generating and displaying the list in that order as defined in features (b) and (c) involves only ordinary programming skills. Hence, regardless of whether features (b) and (c) are technical, they are obvious.

As a result, the board decided that claim 1 lacked an inventive step and dismissed the appeal.

More information

You can read the whole decision here: T 0886/17 (Displaying review information in priority order/Rakuten)

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Withdrawing cash from an ATM via SMS without a banking card: technical but obvious

In this decision, the European Patent Office refused to grant a software patent on the concept of withdrawing cash from an ATM using a payment order delivered via SMS, without the need for a banking card. Here are the practical takeaways of the decision T 2318/13 (Method for obtaining cash at cardless teller machines, using a payment order via SMS) of 26.9.2019 of Technical Board of Appeal 3.5.01:

Key takeaways

Combining banking and cash withdrawal services of different financial institutions: non-technical business idea

The invention

This European patent application generally relates to the problem of allowing a beneficiary to withdraw cash from automatic teller machines (ATM) using a payment order delivered via SMS without the need for any payment instrument, such as a bank card, and type of account.

According to the patent applicant, the invention responded to the need of thousands of immigrants living in developed countries who regularly send money to their relatives in their countries of origin. While SMS services of mobile phones and ATMs were known, no system involving more than one bank had apparently reached the public, due to security drawbacks that arose because two different financial institutions would have needed to exchange client account data.

To solve this problem, the invention proposes the following: An issuing entity (3 in Figure 1) receives a request (1a) for acceptance/cancellation of a payment order from a Principal (2). The issuing entity (3) communicates the order (1b) to a central unit or national ATMPAY module (4), which is separate from the networks of banking institutions and which handles the acceptance/cancellation requests. Once authorised, the beneficiary (6) receives from the central unit (4), via SMS (1d), a reference number, an amount and a PIN code (individual for each operation) which he or she provides to an ATM (7) for withdrawing money from a acquiring entity (8), which may be a different financial institution.

Fig. 1 of EP 1 783 676
Fig. 1 of EP 1 783 676

Here is how the invention is defined in claim 1:

  • Claim 1 (main request)

Is it technical?

The board of appeal started its inventive-step analysis from a prior art document from which claim 1 differed by the provision of a national central module (4) and the associated interactions with it as defined in features (b), (c), (d), (g) and (h). Feature (b) specifies that the issuing entity sends the order to the central module; features (g) and (h) specify that the central module processes requests for authorisation from the acquiring entities; features (c) and (d) specify that the central module uses SMS communication for informing a principal about the authorisation of its order and for sending authorisation information to the beneficiary permitting the withdrawal of money.

First of all, the board assessed the overall drawback to be overcome by the invention, namely the limitation to cash withdrawals from ATMs of the same financial institution:

A business person would recognise the limitation of the business concept of the D1 system, because cash withdrawal was possible only from ATMs of the same financial institution, namely of the principal who requested the money order, see paragraphs [0005] and [0014]. In a situation when thousands of immigrants want to send money regularly to their relatives in their countries of origin, different business needs arise, for example, beneficiaries (in countries of origin) would like to withdraw cash from any ATM of any financial institution and principals would not like to be limited to use a particular financial institution. This boils down to the business idea of making money from a new monetary service which combines banking and cash withdrawal services of different financial institutions, under the assumption that contractual agreements have been reached on the payment of fees, operating expenses and charges for the operations to be carried out, as assumed and recognised in the application, see paragraphs [0021] and [0022]. Even the appellant argued during oral proceedings that the term “national central module” could be seen as sort of new “legal entity” which combines financial services.

The implementation of this business idea was considered straight-forward:

Concerning the means for implementing this new business idea, the Board does not see a reason to disagree with the appellant who stated at the bottom of page 8 of the grounds of appeal, that “all the technical knowledge and tools needed for developing the system of the invention were available from at least 15 years ago. Indeed, the system only requires the use of conventional banking networking tools combination with the SMS service of mobile phones”.

Regarding features (b), (g) and (h), the Board considers it to be obvious to implement these functions as a separate module within the banking system of D1. These functions directly result from the business requirements of the new monetary service which permits different financial institutions to interoperate, such as, to arrange the acceptance / cancellation of payment orders, reporting that the payment order was carried out, to receive authorisation / correction requests for cash withdrawal and to grant them. The implementation of these functions as a module within the D1 system, for example, on the network host computer (20), paragraph [0013], would have been obvious for the person skilled in the art. Also its implementation as a separate “unit” (server) within the D1 system is an obvious design alternative, because D1 already discloses using different servers for different purposes, such as the terminal server, IVR server and back office server.

Aos concerning the feature of using SMS for transmitting the code to the beneficiary, the board decided that this only an obvious implementation of a requirement arising from the business specification:

Turning to the “SMS” feature, see features (c) and (d), the Board agrees with the appellant that the automatic transmission of the code directly to the beneficiary can be seen as being motivated by the desire to avoid fraud of the principal if he or she withdraws the money by himself or herself. The Board judges, however, that such a requirement is also part of the business specification.

The use of SMS communication for the transmission of information to principal and beneficiary was also an obvious implementation of this, because SMS was a well-known communication technology at the priority date of the application.

Therefore, claim 1 was found not to involve an inventive step, and the appeal was dismissed.

More information

You can read the whole decision here: T 2318/13 (Method for obtaining cash at cardless teller machines, using a payment order via SMS)

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Electronic voucher scheme: non-technical

In this decision, the European Patent Office refused to grant a software patent on the concept of replicating the handling and redemption of paper-based vouchers with an electronic voucher scheme. Here are the practical takeaways of the decision T 1031/14 (Electronic vouchers/I-MOVO) of 3.12.2019 of Technical Board of Appeal 3.5.01:

Key takeaways

The idea of not providing the voucher value together with the voucher and distributing vouchers without the notion of an account or balance is a business scheme and does not involve technical considerations.

The invention

This European patent application generally relates to cash value vouchers. According to the description, there is a long history of consumer-oriented businesses using printed cash value vouchers as a promotional tool to retain existing customers and to attract new ones. However, paper-based vouchers suffer from high up-front costs (producing the vouchers, handling), and also consumers increasingly dislike carrying paper vouchers with them. Lastly, paper vouchers of high face-value carry a significant financial risk as advances in copying technology has made it easier to reproduce vouchers fraudulently.

The invention therefore concerns replacing paper-based vouchers by an e-voucher scheme, which is able to work with existing point-of-sale equipment. The overall goal of the invention was to closely replicate how tokens are handled today and effectively dematerialise the token and redemption process.

Here is how the invention is defined in claim 1:

  • Claim 1 (main request)

Is it technical?

First of all, the board briefly addressed the question of patent-eligibility, which was no problem due to the presence of technical means in claim 1:

The claim is directed to a mix of technical and non-technical features. The Board does not dispute that the method according to claim 1 appears in a technical context. The method can be considered to be performed by technical means, because it involves an ISO/IEC 7812-1 and/or ANSI X4.14 compliant POS terminal with means for storing data, means for processing data and means for transmitting and receiving data, and, therefore, has technical character. Accordingly, the claimed subject-matter is an invention in the sense of Article 52(1) EPC (see T 258/03 “Auction method/HITACHI“).

But of course, the challenging test was that of inventive step:

However, the question of inventive step requires an assessment of whether the invention makes a technical contribution over the prior art. Features which do not make such a contribution cannot support the presence of an inventive step (see T 641/00 “Two identities/COMVIK“, Headnote I). The assessment of inventive step in the decision under appeal considered D7 to be the closest prior art.

Accordingly, the board assessed which of the features of claim 1 actually contribute to the technical character of the invention, and came to the following conclusion:

The Board agrees that the following features outlined in point 9.2 of the decision per se pertain to an administrative method, i.e. to the non-technical part of claim 1:

– providing a cash value voucher comprising an alphanumeric number and having a cash value, which cash value is not related to the number, forming a concatenated string comprising said number, terminal identifier and an issuer identification number and sending the string to an acquirer, which acquirer after validating the string sends the string to the issuer, the voucher number having 6 to 10 digits,

– the issuer authenticates the voucher number and amends the string such that the string comprises the cash value, POS terminal identifier and the issuer identification number, which amended string enables authorisation of payment for the value of the cash value,

– the amended string being transmitted via the acquirer to authorise redemption of the voucher for the cash value.

The appellant’s argument that the claimed e-voucher scheme was indeed technical did not succeed:

What the application itself calls “an e voucher scheme” (see e.g. page 1. last par. of the description) is regarded by the Board as an administrative business related concept of distributing, validating and authorising vouchers. The Board does not agree with the appellant’s argument that such a voucher scheme cannot be carried out with pen and paper (see point 6 of the statement setting out the grounds of appeal). It is an abstract concept to issue a voucher not related to a cash value, adding an alphanumeric number, POS ID and issuer ID, validating by an acquirer, authenticating by an issuer to comprise cash value, POS ID and issuer ID, handing it back to the acquirer, who transmits the voucher for authorisation to a dealer. The idea of not providing the voucher value together with the voucher and distributing vouchers without the notion of an account or balance is a business scheme and does not involve technical considerations. The possibility of making different pricing schemes possible is a direct consequence of the business idea. This scheme could be carried out in a conventional way without involving electronic means. It therefore does not contribute to the technical character of the invention.

Also the technical implementation of the e-voucher scheme was not found to involve any helpful technical aspects:

The contribution of the invention does not lie in an improved POS infrastructure for redeeming cash value vouchers. The technical infrastructure used according to claim 1 is that of an ISO/IEC 7812-1 or ANSI X4.14 compliant POS terminal with means for storing data, means for processing data and means for transmitting and receiving data such as a networked general purpose computer, which were common general knowledge before the priority date. The contribution lies rather in the way of associating information with existing transaction data such as cash value, POS ID, issuer ID. Such data, however, in the Board’s view, is not technical, since it is cognitive data, not functional data (see T 1194/97 Data structure product/PHILIPS, OJ EPO 2000, 525).

The appellant had argued that the concatenated string comprised cognitive and functional data and gave an example of a voucher redemption request and a corresponding response message. The appellant also cited a standards-related document that showed that certain fields could not be changed in the response message. According to the appellant, these fields represented functional data, without which the system would not understand the messages. This was said to be analagous to the functional data in T 1194/97 (supra), without which the operation of the television system would be impaired.

But also this argument did not convince the board:

However, the example of a voucher redemption request presented and the changes made to the string therein do not reflect features of claim 1. According to the wording of the claim, the string is amended such that it comprises the cash value, POS terminal identifier and the issuer identification number. These are fields of cognitive data and they do not interact with the system to produce a technical effect as was the case in T 1194/97. They merely enable a business scheme. No further implementation details are given in the claim, in particular it is not specified what the messages look like. Even if the appellant was right with regard to the specific example, which the Board doubts, there is no corresponding concrete feature in claim 1, which could be considered when assessing inventive step.

In the end, therefore, the board decided that in the absence of any technical contribution beyond the straight-forward computer-implementation, claim 1 of the main request did not involve an inventive step. The appeal was dismissed.

More information

You can read the whole decision here: T 1031/14 (Electronic vouchers/I-MOVO)

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Digitalization of the distribution of product inserts: technical but obvious

In this decision, the European Patent Office refused to grant a software patent on a digitalized approach for distributing product inserts. Here are the practical takeaways of the decision T 0223/18 (Product insert update/BIO-RAD) of 18.2.2020 of Technical Board of Appeal 3.5.05:

Key takeaways

Digitalization of the existing workflow for distribution of product inserts: only straightforward implementation of an administrative method using notorious technical means

The invention

This European patent application concerns the digitalization of the existing workflow for distribution of product inserts. According to the application, conventional product inserts were printed and packaged with control products on the basis of information available at the date of manufacture. The invention provided an easy, cost-efficient and targeted way of distributing product insert information.

Fig. 1A of EP 2 567 353
Fig. 1A of EP 2 567 353

Here is how the invention is defined in claim 1:

  • Claim 1 (main request)

Is it technical?

The first instance examining divison had refused the patent application based on the argument that the subject-matter of the claim is the straightforward implementation of an administrative method using notorious technical means such as servers and databases, and consequently does not involve an inventive step. On the appeal stage, the appellant argued that the invention indeed had some business aspects, but that it nevertheless provided an easy, cost-efficient and targeted way of distributing product insert information.

The board was not persuaded:

The board does not doubt that, but the subject-matter of claim 1 does not go beyond the straightforward digitalization of the existing workflow for distribution of product inserts. It uses databases instead of paper for the storage of test data and the parameters derived from them, and servers for their distribution. It is evident that digitized information can be distributed much more easily, frequently, without the costs associated with printing, and that database management systems reply to queries unlike paper which does not.

The appellant also argued that the technical effect was to prevent the distribution of data that might not be accurate. Only when an insert was approved would that insert be transmitted to the end user insert database.

But also this argument did not convince the board:

However, as paragraph [0028] of the application also points out, production of control product inserts is regulated by well-defined FDA-approved procedures that dictate inter alia how insert values are approved. There are equivalent legal or regulatory requirements in every jurisdiction. These requirements for accuracy of parameter values and their approval have to be met, as a matter of course, by conventional printed product inserts that the appellant describes as the prior art. Therefore, the subject-matter of claim 1 cannot have the alleged effect with respect to the prior art.

Lastly, the appellant argued that the method of claim 1 generates more accurate parameters by analyzing data to see if changes occur. However, the board noted that neither claim 1 not the description revealed any information regarding how the data is analyzed  and thus the alleged effect was found to be merely speculative.

As a result, the board confirmed the first-instance decision that claim 1 concerned merely the straightforward implementation of an administrative method using notorious technical means such as servers and databases. Consequently claim 1 was found not to involve an inventive step, and the appeal was dismissed.

More information

You can read the whole decision here: T 0223/18 (Product insert update/BIO-RAD) of 18.2.2020

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