Author Archive

Access-control method for a hearing instrument: non-technical

This decision concerns an invention that relates to an access-control method for a hearing instrument.

Since the distinguishing features were considered non-technical, the EPO refused to grant a patent. Here are the practical takeaways from the decision T 0521/23 (Access-control method for a hearing instrument / SONOVA) July 7th, 2025, of the Technical Board of Appeal 3.5.04.

Key takeaways

A technical effect needs to be credibly achieved over the entire scope of the claim. 

The invention

1.1 The opposed patent concerns a method of controlling access to services provided by a hearing instrument, such as volume control or allowing fitting parameters to be read from and written to the hearing instrument.

The invention addresses safety risks in connection with connecting hearing instruments to external client devices:

1.2 According to the patent, modern hearing instruments can connect to various external client devices, such as smartphones or fitting stations. As set out in paragraph [0003] of the patent specification, a problem with prior-art systems is said to be that, once connected, a client’s applications may have full access to the hearing instrument. This is described as posing a safety risk, as it grants even non-trusted applications the ability to modify safety-critical hearing-instrument configurations.

Fig. 8 of EP 3 542 554 A1

  • Claim 1 of the main request

Is it technical?

D2 is considered as a suitable starting point for assessing inventive step. Featues (a) to (c) are seen as disclosed in D2, this is not contested. The Board makes the following observations regarding the technicalitiy of features (d) to (f):

2.2.1 The respondent submitted that the technical effect to be attributed to the distinguishing features was a “simplification” of the access-control scheme, leading to “low resource requirements”. In support of this, it argued that the skilled reader would always understand the invention in the context of a “hearing instrument”, which was, in the respondent’s opinion, an inherently resource-constrained device, a fact that it considered to be confirmed by document D2 itself (see D2, paragraph [0004]). This echoes Reasons 4.2 of the appealed decision, in which the opposition division, referring to paragraph [0015] of the opposed patent, found the technical effect of the distinguishing features to be “client specific service access requiring low resources”. In that regard, the respondent argued that the claimed method, which relied on a single comparison against a client’s “highest security level” as per feature (d), was inherently simpler than checking a detailed list or matrix of rights for each client, the latter being a method it considered to be representative of the skilled person’s common general knowledge as exemplified in document D8. During the oral proceedings before the board, the respondent attempted to concretise this by giving an example of managing several thousands of hearing-care professionals (HCPs) via a simple classification scheme where all HCPs share the same security level.

2.2.2 The board finds these arguments generally unconvincing. These arguments rely on reading limitations into a claim which are not supported by its wording. They require the skilled reader of present claim 1 to understand the claim in the specific context of a resource-limited device and to assume that the claimed architecture is necessarily implemented in its simplest form. In view of the wording of feature (b), the skilled reader of claim 1 could only speculate as to whether the actual “service” requested by the “client” (being relevant to the performance of method step (d)) is notified by the “client authenticator”, as advocated by the respondent, or by another, yet undefined, data message. In addition, it is not derivable from claim 1 whether, in feature (e), the “security level” to be selected (arguably by an administrator according to the respondent) from many security levels is supposed to refer to the “security level associated with the service request” or to a “security level assigned to the client”, so that the skilled reader cannot even establish whether the “client” is necessarily associated with more than one security level (i.e. “highest security level”).

However, the assessment of inventive step must be based on the whole scope claimed, not on a preferred or commercially advantageous embodiment. The board notes the respondent’s reference to the “business success of respective products” but considers this to be irrelevant to the assessment of inventive step, particularly where a credible technical effect is not established. The respondent’s further example of simplifying the management of several thousands of HCPs by assigning them all to a single security level is equally unpersuasive. As the appellant correctly observed, claim 1 as granted does not relate to such a grouping or classification of clients: this is merely another example of an argument based on a specific, undisclosed implementation rather than on the technical features of the claim itself.

2.2.3 More specifically, the board cannot acknowledge the alleged technical effects of “simplification” or “low resource requirements” as being credibly achieved over the entire scope of claim 1. This is because claim 1 is silent about the resource requirements of the claimed method. It limits neither the number of security levels in the “plurality”, nor the frequency with which the comparison steps are actually conducted. Hence, an implementation with, for example, a complex hierarchy or involving frequent access requests could in fact be resource-intensive. Furthermore, claim 1 as granted does not preclude the possibility of “offloading” computationally intensive tasks to a more powerful peripheral device, such as a smartphone. For this reason, the respondent’s argument that “the skilled reader would not consider complex algorithms when dealing with a hearing instrument” must be discarded.

2.2.4 In view of the above, the board cannot derive any credible technical effect of “simplification” or “reduced resource usage” from the distinguishing features (d) to (f). At most, the effect of these features can be seen as the definition of a particular access-control policy (see also the description as filed, e.g. page 5, line 20 to page 6, line 8). This policy dictates that access is granted if a “requested security level” is below or equal to the “highest security level assigned to the client”. The board concurs with the appellant’s argument, advanced during the oral proceedings before the board, that such a policy is primarily administrative in nature and that its advantages, if any, consequently lie on the administrative rather than the technical side.

2.2.5 Based on the effect identified in point 2.2.4 above and the well-established COMVIK approach (cf. T 641/00, headnote II), the objective technical problem consists therefore, at most, in the technical implementation of this specific, non-technical security policy on the hearing instrument disclosed in document D2.

 

The Board is further of the opinion that the skilled person would have arrived at the solution:

 

2.3.2 The board considers that the skilled person, starting from D2 and seeking to implement the security policy defined in the objective technical problem (see point 2.2.5 above), would have been motivated to use a hierarchical model. The respondent’s argument that the common general knowledge pointed only towards a complex matrix is unconvincing given the ubiquity of hierarchical access-control models. The board further concurs with the appellant that document D2 itself, in paragraph [0038], hints at a multi-level security architecture by disclosing a basic connection authenticated by a pre-established link (such as Bluetooth**(®) pairing) on top of which a further service is authenticated by a digital signature. The respondent’s counter-argument that this merely discloses two sequential authentication steps and not a hierarchy is not accepted. These are two distinct methods for accessing services, implying, typically, different levels of trust and security.

2.3.3 The respondent’s main defence, namely that the skilled person would have been deterred from applying a concept from the field of computer science due to the resource constraints of a hearing instrument, may have convinced the opposition division (cf. Reasons 4.2 of the appealed decision, last sentence) but in the board’s view is without merit. As established in point 2.2.3 above, the claimed method could involve “outsourcing” in the sense that it is at least partially “offloaded” to a more powerful peripheral device: it is not required to be executed solely on a hearing instrument. Even if it were, the board considers that the skilled person would have employed obvious strategies to mitigate resource limitations, such as optimising the security features to minimise their resource footprint or tailoring these features to the specific needs of the hearing device and its user.

The respondent argued that “outsourcing” tasks to a connected device would have led the skilled person away from the claimed invention. This, however, was a mere allegation for which no substantive reasoning was provided. Moreover, the argument misconstrues the board’s reasoning: the board did not suggest “outsourcing” as a step towards the claimed invention, but rather as an obvious alternative strategy available to the skilled person at the relevant date for mitigating resource constraints. The existence of such an obvious alternative undermines the respondent’s argument that their specific on-device solution required an inventive step. The respondent’s own argument that only the most critical steps (e.g. those underlying features (d) and (f)) must be carried out on the hearing instrument itself implicitly acknowledges that other steps can be externalised, further supporting the board’s view.

2.3.4 The board therefore holds that the solution defined by features (d) to (f) would have been an obvious course of action for the skilled person based on the disclosure of document D2 in combination with their common general knowledge.

As a result, the Board came to the conclusion that, in the absense of a specific use of the obtained data, the claimed subject-matter cannot be considered inventive. The same applies to the remaining requests. Thus, the appeal was dismissed.

More information

The decision can be found here: Here are the practical takeaways from the decision T 0521/23 (Access-control method for a hearing instrument / SONOVA) July 7th, 2025, of the Technical Board of Appeal 3.5.04.

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Radioactive Waste Accomodation Method: non-technical

This decision concerns an invention that relates to a radioactive waste accomodation method. 

Since the distinguishing features were considered non-technical, the EPO refused to grant a patent. Here are the practical takeaways from the decision T 1132/23 (Radioactive Waste Accomodation Method / Mitsubishi Heavy Industries Ltd.) July 9th, 2025, of the Technical Board of Appeal 3.4.01.

Key takeaways

In the absence of technical effects going beyond the normal interaction of the algorithm with the computer, the claimed subject-matter could not be considered inventive.

The invention

1. The invention concerns a radioactive waste accommodation method of obtaining a waste body by accommodating a plurality of waste pieces into a storage container.

FIG. 1 is a diagram showing an overall flow of a method for processing radioactive waste. An accommodation condition for accommodating a plurality of waste pieces 900 obtained by cutting radioactive waste 9 into a storage container 91 (91A to 91C) is determined, and the waste pieces 900 are accommodated in the storage container 91 (91A to 91C) in accordance with the accommodation condition to obtain a waste body 950 (950A to 950C).

Fig. 1 of EP 3 300 083 A1

  • Claim 1 of the main request

Is it technical?

The Board found the invention to involve technical means, since the method is defined as a “computer-implemented” method:

1. Claim 1 of present main request was amended during opposition proceedings with regard to claim 1 of the patent, so as to specify that what it defines is computer-implemented. The Board concurs with the Opposition Division, that amended claim 1 of the main request involves technical means and constitutes an invention in the meaning of Article 52(1) EPC. The same conclusion applies to claim 1 of auxiliary requests 1 to 4.

The opponent acknolwedges the involvement of technial means but denies that this affected the inherent nature of the method:

5. The opponent acknowledged that the amendment in the claim, specifying that the claimed method is “computer-implemented”, established the technical nature of the invention, but underlined, under point VI of the statement of grounds, that this did not affect the inherent nature of the recited method steps which relate to mental activities.

It is to be decided whether the features can be considered as technical:

2. The absence, however, of clearly identifiable technical effects derivable from the claim that are achieved by the recited method steps, or derivable from their association, implies that the objective problem of minimising the number of containers needed to store the waste, that has been put forward by the patentee and accepted by the Opposition Division, is too specific since it does not apply over the whole ambit of the claim (see point 8 below).

3. Only the technical effects that are at least implied in the claims should be considered in the assessment of inventive step (cf. decision of the Enlarged Board of appeal G 1/19, OJ 2021, 77, Point 124).

The Board does not recard the features of the pending request to affect the internal functioning of the computer, which consitutes an exception for mathematical models:

4. The method of the various version of claim 1 of the pending requests does not affect the internal functioning of the computer on which it is run. Such implementations are also not addressed in the patent specification. The issue regarding inventive step thus depends on the determination of technical effects that go beyond this mere normal interaction between program and computer.

6. The approach developed by the boards of appeal regarding claims directed to a mix of technical and non-technical features is based on the decision in T 641/00 (COMVIK, OJ 2003, 352) which underlines the necessity, when assessing inventive step, to take account of all those features that contribute to the technical character of the invention, whether they are technical per se or not. Only non-technical features, as such, are ignored. The technical problem to be solved according to the problem-solution approach may be formulated using an aim in a non-technical field.

7. The recited method steps contribute in determining an optimised accommodation condition in terms of place and number of containers (see patent application, paragraph 0007). The problem addressed by the invention is technical. It corresponds to the problem addressed in documents D1a, D1b, and D3.

8. The objective problem identified by the Opposition Division was, hence, to provide an alternative method for minimising the number of required containers for accommodation of the waste pieces.

10. In the absence, however, in claim 1 of the proprietor’s request, of any reference to a specific use of the obtained data, (i.e. the necessary storage container number, the specification of the arrangement condition candidate, the surface dose rate of the waste body…, the objective problem to be solved needs to be defined in more general terms than those suggested by the proprietor and opposition Division for the disclosed invention and its various embodiments (cf. decisions of the Enlarged Board of appeal G 2/03, OJ 2004, 448, point 2.5.2; G 1/19, OJ 2021, 77, point 82, with reference in both decisions to decision T 939/92, OJ 1996, 309). The possible uses of the obtained data regarding the accommodation conditions might well encompass non-technical purposes. This might include, for example, providing the documentation required for administrative authorisations regarding the respect of legal or technical specifications or guidelines as to the storing and transport of waste. The claimed method might also encompass tests for IT experts, asked to elaborate the most efficient algorithm for the task or to compare the performance of computers on which such algorithms are run.

11. Even though the effects relied upon are based on technical considerations, no technical effects other than those resulting from the program running on the computer, namely calculating the necessary storage container number or the arrangement condition candidate and the surface dose rate of the waste body, can be derived from the claim language. In the absence of technical effects going beyond the normal interaction of the algorithm with the computer, the claimed subject-matter cannot be considered inventive.

As a result, the Board came to the conclusion that, in the absense of a specific use of the obtained data, the claimed subject-matter cannot be considered inventive. The same applies to the remaining requests. Thus, the appeal was dismissed.

More information

The decision can be found here: T 1132/23 (Radioactive Waste Accomodation Method / Mitsubishi Heavy Industries Ltd.) July 9th, 2025, of the Technical Board of Appeal 3.4.01.

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User interface for option trading: non-technical

This decision concerns an invention that relates to an electronic trading system. 

Since the distinguishing features were considered non-technical, the EPO refused to grant a patent. Here are the practical takeaways from the decision  T 0374/21 (User interface for option trading/INTERACTIVE BROKERS) October 11th, 2024, of the Technical Board of Appeal 3.5.01.

Key takeaways

The user interacts with data relating to the price of an asset i.e. cognitive data which lacks technical function and character.

The invention

1. The invention concerns a computer-implemented trading tool for generating and displaying trading information and trading strategies for an option.

The trading tool (Figures 2-5) calculates and displays, in a graphical user interface, the probability distribution of prices of the underlying asset for the option based on market data (Market Implied Probability Distribution MIPD). The MIPD is “trimmed” to include only some strike prices (the price at which the underlying asset can be bought or sold by the option holder). The user may customise the probability distribution based on their own estimates (Customized Probability Distribution CPD). Also the CPD is displayed. The tool presents a number of trading strategies for the option based on the CPD, and the user can select a trading strategy to initiate an order.

 

Fig. 2 of EP 3 063 724 A1

  • Claim 1 of the main request

Is it technical?

The examining division considered that the subject-matter of claim 1 was an obvious implementation of a (non-technical) business method on a notoriously known general purpose networked computer system.

The appellant argued that:

1.4 […] the examining division had overlooked interactions between the technical and non-technical features of the claims. In the appellant’s view, the invention was a “technical tool” in the form of a graphical user interface providing a continued and guided human-machine interaction process assisting the user in performing the technical task of adapting a probability distribution of a continuous random variable in a manner which maintained normalisation. The potential for user interfaces providing such functionality to be technical had previously been acknowledged by the Boards of Appeal in, for example, T 336/14 – Presentation of operating instructions/GAMBRO, T 1802/13 – Brain stimulation/CLEVELAND, and T 1185/13.

The Board was not convinced by the argumentation. In particular, the claimed invention assists the user in customising a probability distribution of prices in order to find a trading strategy, which, in the Board’s view, is a non-technical task.

In T 336/14 (at point 1.2.4), a distinction was made between information indicating:

  • an operation state, a condition, or an event internal to the underlying technical system, prompting the system user to interact with it in a continued and/or guided way for enabling its proper functioning (technical),
  • information representing a state of a non-technical application run on that technical system on the other hand (non-technical).

In the context of the invention, the underlying technical system would be the computer system. However, the user rather interacts with data relating to the price of an asset i.e. cognitive data which lacks technical function and character. Thus, the Board judges that the present invention rather falls in the second, non-technical category of information mentioned in T 336/14.

The Board does not not see any technical effect of the claimed invention other than the implementation (in very general terms) of a set of non-technical requirements related to the presentation of information. This implementation would have been obvious to the skilled person.

As a result, the Board came to the conclusion that the subject-matter of claim 1 of the main request lacks an inventive step (Article 56 EPC). The same applies to the remaining requests. Thus, the appeal was dismissed.

More information

The decision can be found here: T 0374/21 (User interface for option trading/INTERACTIVE BROKERS) October 11th, 2024, of the Technical Board of Appeal 3.5.01.

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Electronic payment system: non-technical

This decision concerns an invention that relates to a blockchain generation apparatus and a blockchain generation method that generates blockchain data.

Since the distinguishing features were considered non-technical, the EPO refused to grant a patent. Here are the practical takeaways from the decision  T 0367/21 (Electronic payment system/RICCI) June 6th, 2024, of the Technical Board of Appeal 3.5.01.

Key takeaways

Transferring funds using a SEPA system and making use of a clearing and settlement mechanism are business-related, non-technical requirements.

The invention

1. The invention concerns performing instant payments and other types of financial transactions between payer and payee (“receiver”) without the mediation of a third party.

Looking at Figure 2, in order to start a transaction the payer’s 202 and receiver’s 209 mobile terminals exchange transaction information 1, 2 with each other over a wireless network. Based on this information, the payer’s mobile terminal connects to the payer’s bank 204 and orders it to transfer funds in “real time” to the receiver’s bank 205 (see description, page 2, second paragraph after “Invention summary”). The funds are transferred using a SEPA system or an equivalent one (page 4, third paragraph). The receiver’s mobile terminal then connects to the receiver’s bank 5 to check whether the funds have been received and, if so, sends a confirmation message or provides a payment receipt 6 to the payer.

Fig. 2 of EP 3 164 837 A1

  • Claim 1 of the fourth auxiliary request

Is it technical?

The Board regards the claim as novel and evaluates inventive step in further detail, establishing three groups of features:

A – the two banks are configured to connect “through a SEPA system implementing an interbank network with a Clearing and Settlement Mechanism and being configured to make real time transactions”;

B – the receiving bank makes the funds immediately available on receiver’s account;

C – the second device connects to the receiver’s bank to check the arrival of funds and then confirms the payment by showing a receipt on its display or by sending a confirmation message

 

Feature Group A 

9. SEPA (Single Euro Payments Area) is a payment-integration initiative of the European Union for simplification of bank transfers denominated in euro. It defines a set of interbank rules, practices and standards to be observed by the adherent participants which are of essentially business-related, non-technical nature. In particular, the SEPA scheme is separated from any specific implementing infrastructure, platform or network (see “SEPA credit transfer scheme rulebook”, paragraph 1.5). Similarly, a clearing and settlement mechanism (CSM) is essentially a set of business-related requirements for settling financial transactions.

10. The Board takes the view that transferring funds using a SEPA system and making use of a clearing and settlement mechanism are business-related, non-technical requirements.

11. According to the established case law of the Boards of Appeal, non-technical features do not contribute to inventive step. Instead, they may appear in the formulation of the technical problem, in particular as constraints or requirements to be achieved (see decision T 641/00 – Two identities/COMVIK, Headnotes 1 and 2).

Following this approach, the technical problem solved by feature group A can be formulated as how to transfer funds in real-time between the banks in a manner compliant with the SEPA system and including a CSM.

12. The Board judges that the claimed solution of “configuring” the system accordingly, not adding any further technical features, is a self-evident solution to this problem.

Moreover, conventional network technology already enabled a real-time transfer of information at the publication date of D2 and, technically, the transfer of financial data is not different from the transfer of other types of data.

While SEPA does foresee a (maximum) transfer delay of one business day, this interval is not due to technical, but to administrative issues and can be shortened as desired, for example by means of specific inter-bank agreements (see SEPA credit transfer scheme rulebook, paragraph 1.8)

The Board concludes that the features of group A cannot support an inventive step.

 

Feature B

17. Making the funds immediately available on the receiver’s account is a further administrative, non-technical requirement. This is because the availability of the received funds is not related to any technical characteristics of the receiving bank’s system, but only depends on the bank’s internal administrative rules. Moreover, the claim provides no technical detail as to how this requirement is implemented.

The Board concludes that the feature B cannot support an inventive step.

 

Feature Group C

18. The features of group C concern the way in which the first user is notified of the transfer of funds. The “second device” (e.g. the merchant device) connects to the receiver’s bank and confirms the payment by showing a receipt on its display or by sending a confirmation message.

18.1 The appellant argued that the skilled person would not modify the data flow of D2, and that these features provided the technical effect of “simplifying the process of transferring funds between a payer and a receiver while maintaining a high level of safety”.

18.2 The Board, however, does not see how having the confirmation message sent by the receiver device, rather than by the receiver’s bank, may credibly increase the security of the transaction or otherwise simplify the actual transfer of funds. In the Board’s view, the features of group C merely represent one among the obvious, alternative manners of notifying the first user of the arrival of funds. The Board also observes that most known merchant devices provide some form of visual confirmation to the customer when a transaction has taken place.

The Board concludes that the features of group C cannot support an inventive step.

 

As a result, the Board came to the conclusion that claim 1 of the fourth auxiliary request lacks an inventive step. The same applies to the remaining requests. Thus, the appeal was dismissed.

More information

The decision can be found here: T 0367/21 (Electronic payment system/RICCI) June 6th, 2024, of the Technical Board of Appeal 3.5.01.

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Blockchain generation method: non-technical

This decision concerns an invention that relates to a blockchain generation apparatus and a blockchain generation method that generates blockchain data.

Since the distinguishing features were considered non-technical, the EPO refused to grant a patent. Here are the practical takeaways from the decision  T 0767/21 (Blockchain generation method/NIPPON) of October 10, 2023, of the Technical Board of Appeal 3.5.01.

Key takeaways

While the claimed consensus protocol does not involve any technical considerations, this would probably not be true for all consensus protocols. For example, a PoW protocol taking into account specific hardware factors that make it ASIC resistant would be likely to have technical character (see T 1358/09 – Classification/BDGB ENTERPRISE SOFTWARE, reasons, point 5.5; T 2330/13 – Checking selection conditions/SAP, reasons, point 5.7.5).

The invention

The subject-matter of the application underlying the present decision is summarized as follows in the decision:

2.1 The invention concerns the problem of preventing malicious agents taking control of a blockchain storing a digital currency, thereby being able to falsify transactions, such as spending the same coin twice – “double spending”.

Fig. 5 of EP 337 645 5 A1

  • Claim 1 of the third auxiliary request

Is it technical?

Regarding inventive step, the board chooses D6 as a starting point and consequently avoids discussing the technicality of blockchain technology:

3.5 The Board considers document D6, mentioned in the background art section of the application, as a more appropriate starting point. D6 not only discloses the conventional features of blockchain technology, disclosed in D1 and D2, but also the use of Proof of Stake (POS). This avoids an unnecessary discussion of these features’ technicality (cf. T 550/14 – Catastrophe relief/SWISS RE, reasons, point 3.5). This is particularly prudent where a prominent technology, such as blockchain, is involved and the outcome of such a technicality discussion may have far-reaching consequences for patentability.

It was established that claim 1 differs from D6 by following features:

– blend pattern containing (six) blocks necessary for approving a transaction including at least one of two conflicting parameter types, namely a number of cryptocurrency participants to whom a generating party has transferred coins and a number of coins saved by it.

– A block generation condition checker (125) configured to determine whether the generating party is qualified to generate a new blockchain data, based on the value of the identified parameter (fourth feature).

– An attempt to generate a new blockchain when the block generation condition checker (125) determines, based on the parameter type identified by the parameter calculator, that the generating party is qualified (fifth feature).

Subsequently, the Board and the appellant discuss whether this protocol has a technical character:

3.9 In the Board’s judgement it does not because it is a non-technical policy which is based on business and psychological considerations.

 

Argument 1 – Blockchain consensus protocol is inherently technical:

3.11 The appellant argued that the technical character of the protocol was inherent from the tamper-proof properties of the blockchain. These were such that one could have only developed the claimed protocol having previously understood their technical advantages, especially in terms of security. Without this understanding, the protocol’s development would have been impossible from the outset. If this argument were accepted, the situation here would be similar to that in T 2314/16 – Distributing rewards by assigning users to partial advertisement display areas/RAKUTEN, where in order to devise the concept of dividing a website advertisement area into clickable partial areas and allocating them to influencers, one must firstly understand how a website is constructed on the technical level.

The Board was not convinced by this argument:

3.13 […], the situation here is different from that in T 2314/16, supra. Rather, it resembles the scenario outlined in T 630/11 – Gaming Server/WATERLEAF under reason 11, where a reader who wants to give anon book, which is a technical artefact, as a gift or have a copy of it, is not concerned with technical issues, but rather formulates his desire in terms of the book as an art object.

Argument 2 – Blockchain consensus protocol is comparable to an electronic signature:

3.15 Nor is the Board persuaded by the argument that the claimed consensus protocol is comparable to an electronic signature scheme and therefore technical.

Digital signature schemes are not concerned with the semantics of transmitted information; they operate at bit level. As long as the sequence of bits, transmitted as an electronic message, was created by the signee and was not altered during a transmission, the transmitted content does not play any role. This is fundamentally different from the blockchain consensus protocols which operate at the semantic level and are concerned with ascertaining that the blockchain’s business content accurately reflects business reality over time.

In a final statement, the Board clarifies that:

3.16 The Board notes that while the claimed consensus protocol does not involve any technical considerations, this would probably not be true for all consensus protocols. For example, a PoW protocol taking into account specific hardware factors that make it ASIC resistant would be likely to have technical character (see T 1358/09 – Classification/BDGB ENTERPRISE SOFTWARE, reasons, point 5.5; T 2330/13 – Checking selection conditions/SAP, reasons, point 5.7.5).

As a result, the Board came to the conclusion that claim 1 of the main request lacks an inventive step. Thus, the appeal was dismissed.

More information

The decision can be found here: T 0767/21 (Blockchain generation method/NIPPON) of October 10, 2023, of the Technical Board of Appeal 3.5.01.

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Tracking containers: non-technical

This decision concerns an invention related to tracking and collecting data about containers. The distinguishing features of the main and the first auxiliary request were considered non-technical. Here are the practical takeaways from the decision T 1757/20 (Tracking containers/OWENS-BROCKWAY GLASS CONTAINER) of January 25, 2024, of the Technical Board of Appeal 3.5.01.

Key takeaways

A mere data transmission about the filling of a container is not sufficient for acknowledging a technical effect.

A possible final technical effect brought about by the action of a user cannot be used to establish an overall technical effect because it is conditional on the mental activi­ties of the user.

The term “design of containers” is comparable to a sort of “configuration model”, which belongs to infor­mation modelling, which is, as such.

The invention

The subject-matter of the application underlying the present decision is summarized as follows in the decision:

1.1 The invention relates to tracking and collecting data about reusable containers, see [0001], which are said to be designed and intended to travel repeatedly through an extensive distribution chain, see [0002].

1.2 Data regarding how a particular container travels through the distribution chain is either unavailable or limited, and as such, of little use to the container manufacturer, the initial customer of the container, or to other parties, see [0002].

1.3 The primary purpose of the invention is to track and collect data about containers as they travel through various points in a distribution chain using permanent and unique identifiers for each container, see [0003].

1.4 Paragraph [0060] mentions different usages of the collected data. One usage may be for the manufacturer as feedback to “learn how a particular container design performs” or as feedback “for modifying the design of a container”, which is said to mean to streng­then, lighten or other­wise enhance or optimise container manufacture and/or design with the purpose of a lon­ger lifetime or similar lifetime with reduced weight or increase speed or accuracy in filling. Another usage may be to charge customers for the containers supplied, in particular for implementing different pricing models based on the usage of the containers.

 

 

Fig. 1 and 2 of EP 3 345 135 A1

  • Claim 1

Is it technical?

D1 (WO 2010/009448) was considered as the closest prior art: 

2.3 The appellant alleged that claim 1 differed from D1 by features (F5), (F6) and (F7) which reflect that the claimed containers are “reusable” and that there is a separate manufacturing and filling step, and further by feature (F8). D1 teaches that a con­tainer is manu­factured and filled by the same entity, as shown in Figure 1.

 

Features 5, 6 and 7

The Board concludes that features (F5) to (F7) are known from D1 at the level of generality at which they are claimed.

Feature 8 

2.5 As regards feature (F8), this feature defines the general purpose (“modifying a design”), but not how this is achieved and no active technical effect of how the design of a container can be improved is given. A mere data transmission about the filling of a container is not sufficient for acknowledging a technical effect. The present case is comparable to T 1234/17 where the present Board, in a different composition, found that the provision of a custo­mised design for manu­facturing does not alter the abstract nature of the customised design, see reasons, point 3.2. The Board in that case held that manufacturing an item based on a customised design was certainly a technical problem, but the provision of a specification was not sufficient to acknowledge technical character if the specification does not define how the manufacturing process is controlled in order to produce the item, or what components are to be used in the process.

The Board agrees with the examining division that feature (F8) defines a non-technical administrative constraint.

2.6 Irrespective of whether feature (F8) is interpreted as the possibility of using this data or as actual usage of this data, the usage can be interpreted in light of the description of the application in that the manufacturer learns from it and then mentally decides that a design should be changed. This situation is then similar to T 1741/08, reasons, point 2.1.6, which essentially concluded that a chain of effects, from providing infor­mation, to its use in a technical process, is broken by the intervention of a user. In other words, a possible final technical effect brought about by the action of a user cannot be used to establish an overall technical effect because it is conditional on the mental activi­ties of the user, which might be a person skilled in the art of container design and manufacture.

2.7 The objective technical problem can be formulated as how to gather the necessary data relating to the filling of a container with the purpose of being able to modify a design of the containers, following the COMVIK approach (see T 641/00 – Two identi­ties/COMVIK, OJ EPO 2003, 352). In this approach, the non-technical features can form part of the problem formulation.

2.8 The Board concludes that claim 1 lacks an inventive step (Article 56 EPC) over D1 in combination with common general knowledge, because the person skilled in the art would adapt D1 to implement the administrative scheme of using data relating to the filling of con­tainers as a feedback for modifying a design of the containers.

2.9 The same reasoning applies to claim 1 of the first auxiliary request which only reformulates feature (F8), but does not add any further technical matter. The amendment may clarify that a container is modified based on feedback, as argued by the appellant, but it still does not define how this is achieved on a technical level. The term “design of containers” is comparable to a sort of “configuration model”, which belongs to infor­mation modelling, which is, as such, not an invention for the purposes of Article 52(1) EPC, see T 1389/08, reasons, point 2.

As a result, the Board came to the conclusion that claim 1 of the main request and the first auxiliary request lack an inventive step over D1. However, the case was remitted to the examining division due to procedural reasons.

More information

The decision can be found here: T 1757/20 (Tracking containers/OWENS-BROCKWAY GLASS CONTAINER) of January 25, 2024, of the Technical Board of Appeal 3.5.01.

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Lock screen: non-technical

This decision concerns an invention in the field of mobile communication and more particularly, to a method, system and a mobile communication terminal for performing various functions depending on the number of times or duration of time a button for switching from an inactive state to an active state is pressed.

Since the distinguishing features were considered non-technical, the EPO refused to grant a patent. Here are the practical takeaways from the decision T 2288/22 (Lock screen/FIRSTFACE of July 2, 2024, of the Technical Board of Appeal 3.5.05.

A. Key takeaways

“To display a lock screen in a lock state” relates to a mere presentation of information which does not credibly assist a user in performing a technical task

B. The invention

The subject-matter of the application underlying the present decision is summarized as follows in the decision:

The application concerns displaying a “lock screen” upon activating a mobile terminal and performing user authentication based on a captured image of the user.

Fig. 2 of EP 3 445 076 A1

  • Claim 1 of the main request

C. Is it technical?

First, the distinguishing feature is identified. This is followed by a discussion about the inventiveness of the respective feature.

I. Distinguishing Feature

Appellant emphasizes that

D1 did not disclose, in addition to the distinguishing feature established by the examining division (i.e. […] feature (f)), the part of feature (h) that “the terminal [remains] in the locked state” as well as features (i) and (j) of claim 1.2

The board is not convinced and notes the following:

Regarding feature h

[…] appellant did not argue as to why it considered that it was not disclosed in the passages cited by the examining division. The appellant argued that document D1 “[did] not disclose that the ‘lock screen’ [was] still shown on the display when the authentication [failed]”. However, the board holds that displaying the “lock screen” is not even claimed in the case of a failed authentication.

Regarding features i and j

[…] appellant argued that the “key pattern” of D1 was evidently different from the claimed “pressing of the activation button”. And even if they could be equated to each other, Figure 3 of document D1 disclosed the claimed “pressing of the activation button” and the “activating the camera” in the opposite order. In other words, Figure 3 disclosed “face authentication A3” followed by “determine key pattern A4”.

[…] “activation button” is not limited to a dedicated button and may thus also comprise any other button having the claimed function. Moreover, as to feature (i), the decision under appeal cites steps A1 to A3 of Fig. 3, but not step A4. Hence, it is evident that the examining division mapped the “pressing of the activation button” to the “input key pattern A1”. Since step A1 is disclosed as being performed before steps A2 and A3, the board holds that document D1 in fact discloses these steps in the claimed order.

The distinguishing feature was identified to be feature (f) (i.e., (f) characterized in that, in response to a pressing of the activation button (120) while the terminal (100) is in the inactive state, the microprocessor is configured to operate the terminal (100) to switch into the active state and the display unit (110) to display a lock screen in a lock state)

II. Inventive Step

The board makes following observations:

[…] the distinguishing feature “to display a lock screen in a lock state” relates to a mere “presentation of information” which does not credibly assist a user in performing a technical task (see e.g. T 336/14, Headnote). Hence, it may not support an inventive step (see e.g. T 641/00, Headnote I).

The board does not agree with the appellant’s argument that the distinguishing feature “rendered the system more convenient for the user”. The convenience of a particular method of displaying information may vary based on individual user preferences. Therefore, it cannot be objectively verified.

The board is also not convinced by the appellant’s argument that the examining division’s line of reasoning was based on an “ex post facto analysis” and “slightly illogical”. To the contrary, the board considers that a “lock screen” being displayed in response to pressing a button is notoriously known.

The distinguishing feature of the auxiliary request is also found to relate to mere presentation of information.

The board came to the conclusion that neither the main request nor the auxiliary request is not inventive.

Thus, the appeal is dismissed.

D. More information

The decision can be found here: T 2288/22 (Lock screen/FIRSTFACE of July 2, 2024, of the Technical Board of Appeal 3.5.05.

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Card transaction terminal: non-technical

This decision concerns an application that relates to the field of credit card transaction terminals suitable for use in retail and food services businesses and other establishments that interact with consumers. Since the distinguishing features were considered non-technical, the EPO refused to grant a patent. Here are the practical takeaways from the decision T 1483/19 (card transaction terminal / GOLDMINE WORLD) of February 27, 2023 of the Technical Board of Appeal 3.4.01.

Key takeaways

Providing price information is a non-technical service for informing a customer about a price (irrespective of whether this is before, during, or after a transaction). 

The invention

The subject-matter of the application underlying the present decision can be summarized as follows:

The invention concerns the field of credit card transaction terminals.

More specifically, the present invention relates to point of sale terminals and transactions where the customers of a business may speak a language different from the language spoken by the merchant and the credit card transaction terminal processes transactions in more than one language and displays the correct language for the customer and the correct language for the merchant.

Fig. 1 of EP 2 183 717 A1

  • Claim 1 of the main request

Is it technical?

The Appellant and the Board discussed the inventive step of the main request and the auxiliary requests. D1 which relates to a terminal for a payment transaction using a credit or debit card was seen as the closest prior art. It was mentioned that:

The terminal according to claim 1 differs from that disclosed in D1 in that it further includes a currency module configurable to select an operator currency. This module presents financial information in the merchant and customer interfaces. For the customer interface, the financial information is converted (using exchange rate information) from the merchant’s currency to the customer’s currency. The operator and customer currencies are selected from a plurality of currencies stored in the currency module. The selection can be changed on a per-transaction basis.

In a business environment such as a shop, providing pricing information in a format that is easy for the customer to understand is a service that the merchant offers for business reasons.

The effect of the currency module is that the terminal is able to provide pricing information to the operator and the customer in currency formats that can easily be understood. The skilled person, starting from D1, would be in charge of searching for technical means of providing this additional business service. This is the technical problem to be solved.

In itself, the conversion of a price between currencies is a mental act, based on arithmetic and business information. It takes the price in one currency and multiplies it by a conversion factor. Automating this by retrieving a number representing a price in one currency and a conversion factor from a memory, multiplying them, and outputting the result to make it visible, is a process which the skilled person would have implemented, because it is needed by the business requirement. Implementing this calculation as a module as a part of the terminal described in D1 would have been straightforward.

The Appellant argued that:

[…] D1 did not suggest generating customer currency information. The idea for generating currency information as part of the payment transaction process was not business-motivated because, by the time the price was displayed, the deal had already been made. A business motivation could only be attributed to the phase before the deal was closed. The invention had the effect of removing the need for an extra terminal that generates currency information.

The Board is not persuaded by the Appellant’s arguments and reasons as follow:

Under the COMVIK approach (T641/00 Two identities/COMVIK, OJ EPO 2003, 352), a non-technical requirement can be included as part of the technical problem the skilled person seeks to solve. This is so that the non-technical aspects do not contribute, whether positively or negatively, to any inventive step. It does not matter what motivation may exist for the non-technical requirement. The fact that it is not technical is enough.

In the present case, providing price information is a non-technical service for informing a customer about a price, irrespective of whether this is before, during, or after a transaction. It comes from business considerations. It does not matter, for the purposes of assessing inventive step, whether it is good business or bad. The merchant, as a business person, is providing the customer with information; the skilled person is required to implement that and would have implemented it with the existing terminal, as there would be no need for an extra technical device for converting a price to another currency.

Similar arguments apply to auxiliary request 1 to 4.

As a result, the Board came to the conclusion that claim 1 of the main request and claim 1 of auxiliary request 1 to 4 lack an inventive step. Thus, the appeal is dismissed.

More information

The decision can be found here: T 1483/19 (card transaction terminal / GOLDMINE WORLD) of February 27, 2023.

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Ephemeral group chat: non-technical

This decision concerns an invention related to group text communications between multiple devices, along with communication of associated data and automatic deletion of communications for improved data security. Since the distinguishing features were considered non-technical, the EPO refused to grant a patent. Here are the practical takeaways from the decision T 1959/20 (Ephemeral group chat/SNAP) of November 9, 2023, of the Technical Board of Appeal 3.5.01.

Key takeaways

The feature of deleting all copies of a message after it has been read by all recipients is not based on technical considerations.

The invention

The subject-matter of the application underlying the present decision is summarized as follows in the decision:

“The invention concerns the automatic deletion of messages in group chats, for example in the context of social networks (paragraph [0016]). In particular, the goal is to implement an “ephemeral group chat”, that is, a chat whose messages are automatically deleted when a certain condition is met (for example, when a message has been viewed for a certain amount of time by all recipients, see paragraphs [0016], [0017], [0019]).”

Fig. 2A of EP 3 292 523 A1

  • Claim 1

Is it technical?

D1 (GB 2512140 ) was considered as the closest prior art:

The examining division refused the main request for lack of inventive step in view of “notoriously known mobile client/server systems used for exchanging messages” (referred to in the decision as D0). Documents D1, GB 2512140 and D2, US 2009/248751 were cited as examples thereof.

Board considers that D1 represents a better starting point for assessing inventive step.

Regarding the distinguishing features:

The following features are not regarded as disclosed by D1:

5) receiving, from the second client device, first monitoring information comprising first deletion trigger information;

6) receiving, from the third client device, second monitoring information comprising second deletion trigger information;

7) using the received first deletion trigger information and second deletion trigger information to identify when a deletion trigger associated with the first message has been met;

8) initiating, at said server computer, in response to identifying that the deletion trigger has been met, communications to the client devices associated with said at least three user accounts to implement deletion of the first message.

It was common ground during the oral proceedings that features 5) to 8) enable a coordination of the message deletion in ways not disclosed in the prior art.

The Board judges, however, that the feature of deleting all copies of a message after it has been read by all recipients is not based on technical considerations. Nor does it solve a technical problem. Rather, it is a non-technical requirement expressing a user’s wish or subjective preference. Indeed, the claim is even more general than this, as it does not specify the content of the deletion trigger information, or the corresponding event.

Following the established case law of the Boards of Appeal, non-technical features do not contribute to inventive step but may instead appear in the formulation of the technical problem, in particular as constraints or requirements to be achieved (see decision T 641/00 – “Two identities/COMVIK“, Headnotes 1 and 2).

Accordingly, the Board formulates the technical problem as how to implement the requirement of deleting all copies of a chat message based on the occurrence of an event in all client devices, such as the message having been read by all participants.

The appellant was of the opinion that

[…] even when taking the Board’s problem of implementing the requirements on the system of D1, the skilled person would have handled the deletion of messages on a device-by-device basis, since coordinating this at the central server would have gone against the very teaching of the document.

The Board did not find this argumentation convincing and

[…] recognises that the implementation of non-technical requirements on a technical prior art system might require modifications which, at first glance, appear non-obvious, as there is no technical reason for them in view of the prior art alone. However, since according to the principles of “Comvik” non-technical features cannot contribute to inventive step, the non-technical requirements must be seen as a given, and the skilled person implementing them must make the necessary modifications to the prior art.

As a result, the Board came to the conclusion that claim 1 of the main request lacks an inventive step over D1. The same reasoning applies to the first and the second auxiliary request. Thus, the appeal was dismissed.

More information

The decision can be found here: T 1959/20 (Ephemeral group chat/SNAP) of November 9, 2023, of the Technical Board of Appeal 3.5.01.

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Displaying locations for aircraft landing: non-technical

This decision concerns an invention in the field of avionic display systems and, more particularly, to a flight display system that displays predictive conformal configuration cues for executing a landing after an aircraft engine failure. Since the distinguishing features were considered non-technical, the EPO refused to grant a patent. Here are the practical takeaways from the decision T 0984/22 (Displaying locations for aircraft landing/HONEYWELL) of April 26, 2024, of the Technical Board of Appeal 3.5.05.

Key takeaways

The mere display of landing “locations” in a 3D manner may exclusively be motivated by the subjective preferences of the respective users (i.e. pilots) or the associated GUI designer (absence of technical information to determine landing location = non-technical).

The invention

The subject-matter of the application underlying the present decision is summarized as follows in the decision:

1. The present application concerns an avionic flight display system that is supposed to display predictive cues for executing aircraft landing by a pilot after a “loss of engine thrust”.

Fig. 5 of EP 3 029 653 A1

  • Claim 1 of the main (sole) request

Is it technical?

Following points regarding claim construction were discussed:

2.1.1 As to features (i) to (iii), the board notes that these features do not mandate displaying an actual “location” on a map. Rather, features (i) to (iii) merely require the display of “unique conformal cue[s] for … the location where the aircraft will land in relation to the runway”. The board considers that the term “cue for the location” encompasses any information indicating such a location (see point 2.7 below).

2.1.2 As to feature (b), the board is not convinced by the appellant’s interpretation that the term “loss in engine thrust” implied a full or at least significant loss of thrust. Rather, the board holds that the extent of the loss is not quantified in claim 1, neither expressly nor implicitly. In addition, contrary to the appellant’s view, the term “loss” does not imply an involuntary loss. Likewise, the board does not share the appellant’s view that it was necessarily irreversible, as opposed to, for example, a reduction of thrust performed by the aircraft’s pilot. Rather, the board considers that the term “loss” does not imply any restriction as to its cause. In other words, the expression “loss in engine thrust” is not limited to an “engine out emergency” situation and may also comprise any partial “loss in engine thrust”.

Subsequently, the Board discussed each feature in relation to the closest prior art D6 (US 4 825 374 A):

Feature (i) – result: anticipated by D6

2.2 According to document D6, the landing location information is shown as an indication whether the aircraft is descending at the optimum calculated rate (or above/below this rate, respectively) in order to reach a “programmed descent point” (see column 9, lines 26-39 and lines 58-63 of D6). This “descent point” is disclosed as being, for example, an airport runway (see column 8, lines 4-8 of D6). Thus, the board holds that feature (i) is already anticipated by document D6.

Feature (ii) and feature (iii) – result: distinguishing features

2.3 On the other hand, the board finds that D6 does not directly and unambiguously disclose features (ii) and (iii) of claim 1. Notably, “guideslope marker 74” of D6 cannot anticipate a “cue” for a landing location if only a “landing gear” is deployed, since it is disclosed as being always located concentrically within the idle descent marker (see column 9, lines 20-24). The board thus concurs with the appellant that those features constitute distinguishing features.

2.4 As to feature (b), the appellant argued that the “current aircraft configuration” was one where there was no “engine thrust” whereas the “idle condition” disclosed in D6 clearly envisaged the engines being in a fuel-consuming idle condition. However, in view of the interpretation set out in point 2.1.2 above, the “idle condition” mentioned in document D6 falls well within the broad scope of the phrase “loss in engine thrust”.

2.5 In consequence, the subject-matter of claim 1 differs from the disclosure of document D6 in that the cues are displayed responsive to detecting the loss in engine thrust on a three-dimensional display and relate to landing locations in situations where only a landing gear or where both landing gear and flaps are deployed, while also the terrain is updated, i.e. features (b), (ii), (iii) and (c).

The appellant suggests technical effect (assisting the user in safely landing the aircraft) and objective problem (“providing to a pilot guidance for safely landing an aircraft in case of engine failure”.)

2.6 The technical effect resulting from those distinguishing features was extensively discussed during the oral proceedings before the board. In that regard, the appellant argued, by referring to T 336/14 and T 528/07, that providing cognitive information about a state of a technical system already implied a prompt to the user (i.e. the pilot) to act in accordance with this information (i.e. to deploy landing gear, flaps when indicated). The technical effect of the distinguishing features consisted in assisting the user in safely landing the aircraft. On that basis, the appellant argued that the present invention solved the objective problem of “providing to a pilot guidance for safely landing an aircraft in case of engine failure”. Document D6 could not hint towards a solution to this problem, since it presupposed that it was possible to also increase engine thrust during landing (referring to column 10, line 13: “aircrew must add power”).

The Board believes that:

Even if “safely landing an aircraft” could indeed be considered a “technical task” within the meaning of T 336/14, the distinguishing features and claim 1 as a whole are not suitable to credibly assist the user (i.e. the pilot) in performing such a technical task by means of a continued and/or guided human-machine interaction process (cf. T 336/14, Reasons 1.2).

The Board further elaborates that:

In particular, claim 1 is entirely silent as to how the respective “locations” are actually determined upon detecting a “loss in engine thrust” (whatever its precise scope, see point 2.1.2 above). Those additional “locations” according to features (ii) and (iii) could even correspond to a “first guess” possibly based on, for example, previously obtained data or be taken from flight simulation data. No mathematical operation or any measurements whatsoever – as invoked by the appellant – are in fact derivable from the wording of claim 1. Consequently, those “locations” do not necessarily reflect any “technical conditions” (within the meaning of T 528/07, Reasons 3.4 and 3.5, as cited by the appellant) or the actual “operating state” of the underlying technical system (i.e. the aircraft here). Hence, these landing “locations” do not credibly correspond to “technical information” within the meaning of T 336/14 (cf. Reasons 1.2.4).

The Board comes to the conclusion that:

In the absence of “technical information” being required to be involved in the determination of those landing locations, the mere display of those landing “locations” in a 3D manner may exclusively be motivated by the subjective preferences of the respective users (i.e. pilots) or the associated GUI designer – without the need of any technical expertise. Therefore, applying the well-established COMVIK approach (cf. T 641/00, Headnote II), the objective technical problem could, at most, be framed as “how to technically implement the display of further – somehow obtained or estimated – landing locations on the aircraft display used in D6”.

The Board believes (uncontested by the appellant) that the technical implementation was notoriously known at the priority date of the present application:

2.8 The board, however, considers that displaying an aerial view of a particular region in a three-dimensional way to a user together with an indication of the current aircraft position and a certain flight destination along with some undefined “landing locations” was notoriously known already at the priority date of the present application (i.e. December 2014). In avionic systems, moving-map displays, designed for example for passengers, were introduced already in 1982, while visualising some “landing location data” is already known from D6. This was not contested by the appellant. Thus, the board judges that it would have been obvious to the person skilled in the field of avionic GUIs to come up with the claimed solution in view of the above objective technical problem to be solved.

As a result, the Board came to the conclusion that claim 1 of the main request lacks an inventive step. Thus, the appeal was dismissed.

More information

The decision can be found here: T 0984/22 (Displaying locations for aircraft landing/HONEYWELL) of April 26, 2024,of the Technical Board of Appeal 3.5.05.

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