Determination printed content based on a user’s selection of an interface zone: non-technical

The application underlying the discussed decision concerns an interactive terminal (kiosk) designed to randomly print literary content, such as poems or short stories, upon a user pressing one of several interface buttons. The key feature at issue was the random determination of the printed content based on the user’s selection of an interface zone, with two successive presses generating two different printed outputs. The Board of Appeal considered this feature non-technical, as it merely defined subjective criteria for selecting cognitive content based on presumed user preferences for an entertaining experience.

Here are the practical takeaways from the decision: T 0992/20 (Textes aléatoires/SHORT EDITION) of 19 November 2025, of the Technical Board of Appeal 3.5.01.

Key takeaways

The invention

The Board of Appeal summarized the invention as follows:

The invention relates to an interactive terminal (kiosk) for printing content, in particular literary texts such as poems, short stories, or comic book excerpts. The terminal comprises a self-supporting structure, a user interface with at least two distinct interface zones (e.g., push buttons), a built-in printer, and an electronic unit running a program. Each interface zone corresponds to a characteristic of the content to be printed, for example reading duration such as one minute, three minutes, or five minutes. When a user presses a button, the program randomly selects content matching the corresponding characteristic and prints it. Two successive presses on the same button generate two different printed outputs, ensuring unpredictability for the user. The invention aims to make the interactive terminal experience more entertaining and playful by providing content whose exact nature is not entirely determined by the user’s choices. The terminal is intended for public spaces where people may need to wait, such as queues at service counters. Known interactive terminals either print content entirely determined by user choices or content determined solely by the electronic unit (e.g., queue ticket numbers), but none combine selective user input with random content generation.

Is it patentable?

The Examining Division’s position

The Examining Division rejected the application on the ground that claim 1 of the sole request lacked inventive step. The closest prior art, D1 (US 5615123), disclosed an interactive terminal for printing content such as texts or images, comprising a self-supporting structure, a user interface with at least two distinct interface zones, a built-in printer, and an electronic unit executing a program to automatically print content in response to a selective button press. The Examining Division found that the distinguishing features over D1, namely the random determination of printed content and the requirement that two successive presses generate different outputs, constituted an implementation of administrative constraints on the known technical infrastructure of D1. Document D4 (US 4712174), referenced by D1, was cited as an example of random content generation. The implementation of such constraints on the known system was considered obvious.

The Appellant’s arguments

1. The Appellant argued that D1 could not be considered the closest prior art because its purpose was fundamentally different, namely “the creation of printed cards from pre-registered templates by entering wishes,” whereas the invention aimed at providing unpredictable, entertaining content.
2. The Appellant drew a parallel with so-called “problem inventions” (citing decisions T 2/83 and T 225/84), arguing that even if the solution was obvious, inventive step resided in the identification of the problem itself, namely how to make an interactive literary content terminal attractive and entertaining for a large number of users.
3. The Appellant invoked the commercial success of the invention as a secondary indicator supporting the presence of inventive step.
4. During oral proceedings, the Appellant contended that random generation of texts had technical character because it required specific algorithms for its implementation.

The Board’s analysis

Main Request

1. The Board agreed with the Examining Division that the differences between claim 1 and D1 were: (a) the content to be printed is randomly determined, and (b) two successive presses on the same interface zone generate two different printed outputs.
2. The Board held that these differences essentially define a set of criteria or constraints for selecting the cognitive content of printed texts. These constraints are not based on objective technical considerations but exclusively on a subjective assessment of the user’s presumed preferences, with the aim of offering an entertaining experience (description, page 3, lines 9 to 12).
3. Citing T 306/10 and T 2469/12, the Board reiterated the established principle that the selection and presentation of information based on subjective user preferences is not considered a goal to be achieved in a technical field.
4. Consequently, the distinguishing features are non-technical and do not contribute, either individually or in combination with other features, to the technical solution of an objective technical problem. Under the COMVIK approach (T 641/00), they may legitimately be incorporated into the formulation of the technical problem as constraints to be met.
5. Since implementing these constraints on the known terminal of D1 posed no technical difficulty, claim 1 lacked inventive step.
6. Regarding the Appellant’s arguments: D1 was considered appropriate closest prior art because, like the invention, it disclosed an interactive terminal for printing texts where user selection drives content output. The “problem invention” argument was rejected because the identified problem (making the terminal attractive/entertaining) depended on user psychology and subjective reactions and was therefore not a technical problem (citing T 1025/08). The commercial success argument was dismissed because the non-technical differences meant that any success was attributable exclusively to the underlying commercial idea (citing T 633/07 and T 456/90). Finally, the argument that random generation requires algorithms was rejected because the mere implementation of a commercial idea does not retroactively confer technical character on the idea itself.

Auxiliary Request I

1. Auxiliary Request I added the feature that the program determines an incremented number and/or code at each new selective press, printed alongside the content. The Board found that this feature derived obviously from administrative constraints (e.g., queue management or user numbering) and likewise lacked inventive step for the same reasons as the main request.

Auxiliary Request II

1. Auxiliary Request II, filed during oral proceedings, added “so as to manage a queue of users.” The Board did not admit this request under Article 13(2) RPBA, finding that the issue of whether queue management functionality was included in the claims was not a new objection but a normal development of the discussion on inventive step, and thus did not constitute exceptional circumstances.

Conclusion

The appeal was dismissed. The Board confirmed that the random selection and printing of content based on subjective user preferences constitutes a non-technical feature that cannot support inventive step. The fact that users may find the experience entertaining or playful is a subjective, psychological effect, not a technical one. Under the COMVIK approach, such features are included in the problem formulation as constraints to be met, and since their implementation on the known terminal of D1 was straightforward, none of the admitted requests involved an inventive step within the meaning of Article 56 EPC.

More information

You can read the full decision here: T 0992/20 (Textes aléatoires/SHORT EDITION) of 19 November 2025, of the Technical Board of Appeal 3.5.01.

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