The European Patent Office refused to grant a patent on a GUI design of a household appliance such as a baking oven. Here are the practical takeaways of the decision T 1818/14 (User interface for appliance/ELECTROLUX) of 2.12.2019 of Technical Board of Appeal 3.5.03:
This European patent application concerns a user interface for an appliance such as a baking oven. Essentially, as defined in claim 1, the user interface has a controller for controlling a display panel which has first and second display panel sections. The first display panel section displays at least one of a time course and chart of linear, arrowed or curved geometry of at least one operation parameter, and the second display panel displays an operational mode of the appliance, the operational mode being represented by an animated graphics icon, the animated graphics icon being a superposition of at least one pictogram and an image sequence of several images.
Here is how the invention is defined in claim 1:
Claim 1 (main request)User interface adapted to an appliance of household or industrial type selected from the group consisting of baking ovens, microwave ovens, washing machines, dishwashers, refrigerators and freezers, comprising a display panel (1), and a controller adapted to controlling the display panel (1), and adapted to processing operational parameters of a preset or user defined program into display information, wherein the controller is adapted to display in a first display panel section (7) of the display panel (1) at least one of a time course (2, 3, 4, 5, 6) and chart of linear, arrowed or curved geometry of at least one operational parameter, and wherein the controller is further adapted to display in a second display panel section (9, 10), other than the first display panel section (7), an operational mode of the appliance, the operational mode being represented by an animated graphics icon, and the animated graphics icon being a superposition of at least one pictogram (12) and an image sequence (13) of several images.
Is it technical?
The board based its inventive step reasoning on a prior art document which discloses a baking oven with a user interface. Implicitly, the user interface was controlled by a controller. There were also first and second display panel sections.
According to the board, claim 1 differed from this disclosure in that the animated graphics icon consists of a superposition of at least one pictogram and an image sequence of several images. Here is what the board said regarding the technical character of this difference:
In accordance with case law (cf. e.g. T 1185/13, point 4.1 of the reasons), the manner of presentation of information, i.e. how it is displayed, may relate to solving a technical problem and thus be able to contribute to inventive step if the way the information is displayed credibly assists the user in performing a technical task.
In the present case, the distinguishing features have no technical effect beyond the technical details of implementing an icon with a static part and an animated part. In particular, there is no improvement in the ability of the user to operate the oven by enabling further indications of the operational mode to be displayed, as argued by the appellant. In this respect, the animated graphics icon may be nothing more than a foreground representation of an oven with a background image sequence of burning wood, or a foreground picture symbolising the operational mode and an image sequence representing a fireplace with glowing coals (cf. paragraph  of the description), which, when compared with D4, merely concerns a more aesthetically pleasing way of displaying the operational mode. Consequently, any improvement here lies within the field of a presentation of information (cf. Article 52(2)(d) EPC). Using the established COMVIK approach (cf. T 641/00), this aspect therefore does not contribute to inventive step.
The technical problem therefore reduces to that of how to implement technically an animated graphic icon consisting of a static part and a dynamic part. The claimed solution, i.e. the superposition of a pictogram and an image sequence, is deemed to be obvious to the skilled person based on common general knowledge, as it is well known that simple animation can be produced by a sequence of image frames (e.g. of a ball) superimposed on a background. A well-known example of this type of animation is the use of multiple image layers in the context of GIF (cf. EP 1 107 605 A2 (= D7), paragraph , which refers to the prevailing state of the art). Further, in the case of D4, it is obvious that the “square box” part of the icon could be a static “pictogram”, and the changing grill bars could be represented by a sequence of images. Furthermore, the appellant has not claimed that creating simple animation in this manner was per se not known in the art.
Therefore, the board concluded that claim 1 lacks an inventive step and dismissed the appeal.
You can read the whole decision here: T 1818/14 (User interface for appliance/ELECTROLUX) of 2.12.2019
Bastian is a European patent attorney at BARDEHLE PAGENBERG. He specializes in software patents in Europe both from a prosecution and litigation point of view.