The application concerns methods and devices for management of resources and of traffic flow related to the transfer of goods, especially containerised goods, by truck, to and from a terminal, such as a shipping terminal. Both the Examining Division (ED) and the Board of Appeal (BoA) held that the claimed subject matter is not inventive over D5 (US 2009/021347 A1).
Here are the practical takeaways from the decision: T 0754/22 of November 4, 2025, of the Technical Board of Appeal 3.5.01.
Key takeaways
Scheduling trucks into specific time-slots to avoid too many trucks showing up at once is a non-technical activity.
Bonus effects, even if they were considered technical, do not confer technical character upon the scheduling method and, therefore, cannot support an inventive step.
The invention
The BoA summarized the invention as follows:
1.1 The invention relates to managing the traffic flow at a shipping terminal where containers are transferred between vessels and trucks.
Typically, trucks arriving at the terminal are serviced on a “first come, first-served” or “first in, first out” (FIFO) basis resulting in inefficiencies, delays and causing pollution (see page 7, lines 6 to 18 of the A1 publication).
1.2 The core idea of the invention is to allocate specific time-slots to trucks, ensuring that each truck aligns its arrival at the terminal with its assigned time slot (page 14, lines 1 to 15).
A terminal operator manually allocates resources and corresponding time-slots to service vessels and trucks. This information is entered into a reservation system’s database (page 15, lines 1 to 27). As illustrated in Figures 3A to 3D, a truck operator can access the system remotely, reserve a time-slot for truck service, and enter various details such as the truck’s license number.
1.3 The system incorporates dynamic rescheduling: In the event of schedule disruptions, warning messages are dispatched to truck drivers affected by the changes (page 22, lines 27 to 31). Conversely, if a truck driver experiences delays, he can communicate this to the reservation system, which then provides a new time-slot (page 25, lines 14 to 20).
1.4 The reservation system timely alerts the truck driver to proceed to the designated lane at the terminal entrance, which is obstructed by a barrier. When the truck reaches its turn, a “truck-identifier device” scans the license plate (“identity” in claim 1) and transmits the information to a terminal control system. This system then verifies the match with the reservation, and if successful, the barrier is opened (page 39, line 9 to page 40, line 5).
Fig.2 of EP2805290
-
Claim 1 of the main request reads as follows (feature labelling by the Board):
Is it patentable?
The BoA judges that claim 1 is not inventive over D5 and the skilled person’s common general knowledge:
2.1.2 It differs from claim 1 in features F1 to F7 and in the data used for the discrepancy check in feature F11.
As explained in the following, the distinguishing features boil down to a scheduling method, i.e. a non-technical activity scheduling trucks into specific time-slots to avoid too many trucks showing up at once.
These activities include: providing time-slots available for servicing trucks at the terminal, based on certain criteria (F2); a trucking operator reserving a time-slot, not more than 30 minutes long, for a specific truck and service (F1, F3); moving the reserved slot from an “available” list to an “unavailable” list (F3); associating the reserved slot with information about the truck and the service to be performed (F4); a terminal operator allocating resources to service vessels, which causes certain time-slots to become unavailable (F5); notifying a truck driver of any changes to the reservation (F6); allowing a truck driver to report delays in real-time (F7); and allowing a truck to enter the terminal when it arrives at the reserved time-slot (F11).
2.1.3 Essentially, the distinguishing features define a method that allows a terminal operator to set available time-slots for servicing trucks, enables a truck operator to book a time-slot, and by which the parties involved can communicate changes to the schedule.
Choosing and setting up a scheduling method generally does not require any technical insight. For example, appointments at a doctor’s office, repair shop, or hair salon typically follow a bookable time-slot model rather than a walk-in basis. In practice, it is usually the shop owner or manager who defines the scheduling rules, such as how far in advance customers may book, the duration of time-slots, or whether appointments are required at all. These are administrative decisions which do not require technical skill or address a technical problem. Technical aspects become relevant only in the implementation of such a scheme.
The appellant argued that the claimed reservation system generated an output signal to physically open a barrier which was a technical solution to the problem of “reduc[ing] the time trucks wait in the FIFO queue of a terminal without adversely affecting the needs of the ships”. In the appellant’s view, this resulted in further technical effects such as improved usage of the terminal’s resources or reduced carbon emissions (see statement of grounds of appeal, first half of page 5). However, the BoA did not agree:
2.2 … First, the Board notes that not the reservation system, but the control system using data from the reservation system opens the barrier. This is also the case in D5 (see paragraph [0050]).
Second, while scheduling through bookable time-slots may indeed be more efficient, i.e. resulting in a reduced waiting time or improved resource management, than other approaches – such as a “first come, first served” system (FIFO queue) – this is an inherent property of the scheduling method itself and as such cannot be considered a technical effect. Other possible effects or benefits such as improved working conditions for truck drivers or reduced carbon emissions are, if at all, a direct and inevitable consequence of the scheduling method and therefore mere bonus effects. Such effects, even if they were considered technical, do not confer technical character upon the scheduling method and, therefore, cannot support an inventive step.
In the end, the BoA concluded that the subject-matter of claim 1 does not involve an inventive step (Article 56 EPC).
More information
You can read the full decision here: T 0754/22 of November 4, 2025, of the Technical Board of Appeal 3.5.01.