The European Patent Office a more efficient approach for processing database transactions to be technical. Here are the practical takeaways from the decision T 0568/17 (Database transactions/OPEN TEXT SOFTWARE) of 28.7.2020 of Technical Board of Appeal 3.5.07:

Key takeaways

A reference to OLAP systems does not anticipate a particular way of performing transactions.

The invention

This European patent application relates to providing support for ACID-compliant database transactions (atomic, consistent, isolated and durable) in databases that employ an index structure based on the principle of “compressed inverted indices”. The transactions operate on data entities, which are identified by unique identifiers.

The invention proposes to provide the database as an ordered set of data stores, each data store storing versions of one or more data entities. The data stores are ordered from least recent to most recent. The version of a data entity in the most recent (“newest”) data store is the currently valid version of the entity. If a transaction comprises insert, update or delete operations, new or modified versions of data entities are stored in a newly generated “modifiable” data store. When the transaction is committed, the modifiable data store is added to the ordered set of data stores as the “newest” data store.

Fig. 5 of EP 2 467 791
Fig. 5 of EP 2 467 791

Here is how the invention was defined in claim 1:

  • Claim 1 (main request)

Is it patentable?

The first-instance examining division had decided that the subject-matter of independent claim 1 of the main request was not new over document D1. The board did not agree:

Document D1 relates to the construction of an inverted index for high-dimensional data (see paragraph [0025] and claim 1). It does not disclose transactions, let alone a detailed mechanism for performing transactions as specified in claim 1 of the main request.

The Examining Division, in point 3.1 of the communication containing the reasons for the decision, apparently considered that “efficient transaction processing” was implicitly disclosed by the reference to current Online Analytical Processing (OLAP) systems in paragraphs [0009] and [0010] of the background section of document D1.

However, a reference to OLAP systems is far from a disclosure of a particular way of performing transactions.

Furthermore, the examining division had stated in its decision that it considered the term “transaction” to mean “any item which is processed within a computer system”. Also this assessment was turned over by the board:

Although this statement may explain why the Examining Division considered transaction processing to be implicit in OLAP systems, it also shows that the Examining Division failed to appreciate that claim 1 relates to the processing of a database transaction in the normal sense of the term, which is not any processed item but a unit of work that, in particular, is executed atomically, i.e. executed completely (and then “committed”) or not at all (with partial changes to the database being rolled back).

As to the claimed “ordered set of data stores”, which is an essential part of the invention’s mechanism for performing transactions, the Examining Division only stated that “the data source(s) from which data is received [in an OLAP system] can either be internal or external to a particular database system”.

But such a plurality of data sources does not disclose an “ordered set of data stores” to which a committed transaction commits a newly generated data store “as newest data store”.

As a result, the board concluded that claim 1 was novel over D1.

Moreover, the technical character of the above distinguishing features was not challenged by the board, but with respect to inventive step the board stated:

Moreover, since document D1 neither relates to providing support for database transactions nor discloses any of the key features of the invention, it cannot be regarded as a promising starting point for assessing inventive step. Therefore, it does not render the subject-matter of any of claims 1 to 15 obvious.

Since the board had doubts whether the search had  been carried out completely, the case was remitted back to the first instance for further prosecution.

More information

You can read the whole decision here: T 0568/17 (Database transactions/OPEN TEXT SOFTWARE) of 28.7.2020

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