This decision relates to a European patent application concerning a method and a system for authorising access to goods and/or services based on an access voucher. Here are the practical takeaways from the decision T 0800/20 (Restricted voucher redemption/MICROTRONIC) of 10.10.2022 of Technical Board of Appeal 3.5.01:
Key takeaways
Restricting the redemption of a voucher to a particular machine is not a technical problem, and providing an identifier, such as a name or a number, for identifying the machine is an administrative matter.
The invention
The invention concerns a method for obtaining goods from a vending machine using a prepaid voucher and seeks to ensure that the vending machine accepts only vouchers directed to it and restricted to goods which it serves. Claim 1 of the main request concerns a method carried out by the vending machine (“point of sale” in the claim) upon reading such a restricted voucher.
As shown in Figure 2, the voucher comprises the identifiers of goods for which it can be redeemed (31) and the identifier of a vending machine to which it is directed (32). While not claimed, the identifiers might be, for example, encoded in a scannable QR code.
The vending machine stores the list of identifiers of served products (21) and its own identifier (22) in databases 201 and 202. Upon reading the voucher, the vending machine extracts the identifiers 31 and 32 and compares them with the stored identifiers 21 and 22. If the corresponding identifiers match, the product can be dispensed (“the access to goods…being authorised”).
Figure 2 of EP2912615
Here is how the invention was defined in claim 1:
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Claim 1 (main request)
Is it patentable?
The examining division refused claim 1 for a lack of inventive step over D1 (Article 56 EPC).
The Board confirmed the decision of the examining division:
2.5 Accordingly, using the numbering of the features in point 3.2 of the decision under appeal, the Board considers that the subject-matter of claim 1 differs from D1 in that:
i) The voucher and the vending machine comprise the identifier of the vending machine.
ii) The vending machine authorises the access to goods if the identifier of the vending machine read from the voucher matches the corresponding identifier stored in the vending machine.
2.6 Applying the COMVIK approach (T 641/00 – Two identities/COMVIK), it is common ground that the distinguishing features implement a non-technical administrative requirement whose specification is given to the skilled person within the framework of the technical problem to be solved. The point of dispute is the scope of this requirement specification.
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2.8 In the Board’s view, restricting the redemption of a voucher to a particular machine is not a technical problem, and providing an identifier, such as a name or a number, for identifying the machine is an administrative matter. Thus, it follows that the non-technical requirement specification dictates that the voucher should be associated with a vending machine identifier, and this identifier should be compared with the identifier of a vending machine to which the voucher is presented.
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2.10 In their ancillary line of reasoning, the examining division argued that, even assuming that the decision to provide the vending machine identifier in the voucher had technical character, it was still an obvious design option. The same held for providing the identifier in the vending machine (decision, point 5).
The Board agrees and judges that starting from the embodiment of D1 in which the voucher has all the relevant redemption features and given the problem of implementing the requirement specification defined in point 2.8, it would have been obvious to provide the vending machine’s identifier in the vending machine and on the voucher and to adapt the vending machine to compare these identifiers when the voucher is read.
In the end, the Board judges that claim 1 (main request) lacks an inventive step (Article 56 EPC). Since none of the auxiliary requests could overcome this objection, the application was finally refused.
More information
You can read the whole decision here: T 0800/20 (Restricted voucher redemption/MICROTRONIC) of 10.10.2022 of Technical Board of Appeal 3.5.01.