This decision concerns an European patent application relating to a method of reserving compartments. Here are the practical takeaways from the decision T 1203/20 of January 25, 2024, of Technical Board of Appeal 3.4.03.
Key takeaways
An administrative scheme of managing compartments will be provided to the skilled person as non-technical constraints for implementation.
Automating steps of a manual process has always been considered a pervasive aim in any technical system.
The invention
The invention relates to reserving compartments in a post system. The post system comprises compartments (lockers) which can be reserved by users. The system maintains a database with records including the status of each compartment (“reserved” – “available”) and when it receives a request for a reservation it looks for available compartments on the basis of their status as stored in the database.
Reservations are made for a certain period of time, i.e. they have a start and an end time. The system monitors the time and when the end time of a reservation passes, it changes automatically the status from “reserved” to “available” unless it detects that there is a package in the compartment.
Figure 1 of EP2927884
Here is how the invention was defined by independent claim 10 of the main request:
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Claim 10 (system claim) of the main request
Is it patentable?
The examining division found that claim 1 lacks an inventive step. The applicant appealed but was unable to change the outcome of the case. The following references are cited in the decision:
D1: US 2002/0080030 A1
D4: US 2003/0222760 A1
Main request
Regarding the main request, the Board considered D1 as a suitable starting point for the assessment of inventive step, wherein the following features were considered as distinguishing features of claim 10:
- (i) the post system is adapted to identify at least one record within the reservation table of the database associated with a reserved compartment having a reservation time that is past a current time, and to update the record of the reservation table corresponding to the identified compartment to available;
- (ii) wherein the identifying at least one record further includes comparing the reservation time with the current time and data from a recognition means, the recognition means provided at the one or more compartments and adapted to recognise if a package is deposited in a compartment, wherein the record corresponding to the reserved compartment is updated to available if the recognition means do not detect that a package has been deposited in the reserved compartment within the reservation time; and
- (iii) the post system is adapted to update the reservation table by storing data indicating a reserved status associated with the at least one available compartment to be reserved and a reservation time to establish a compartment reservation.
However, the Board considered that the distinguishing features are not technical and thus found that the subject-matter of claim 10 of the main request does not involve an inventive step (Articles 52(1) and 56 EPC):
2.5.1 As stated previously, the board considers that the difference between the claimed system and the system of D1 lies in the way they are managed. The identified distinguishing features represent thus an implementation of an administrative scheme for managing the compartments.
According to established case law and practice, the board considers that the administrative scheme of managing the compartments will be provided to the skilled person as non-technical constraints for implementation. Any technical problem present would relate merely to how these non-technical constraints are (to be) implemented.
As stated previously, the system of D1 comprises all the necessary technical means for implementing the administrative (business) scheme underlying the claimed system. The board’s view is therefore that such an implementation would be obvious to the skilled person using common general knowledge.
First auxiliary request
The system of claim 8 of the first auxiliary request (based on claim 10 of the main request) comprises additional features enabling it to receive an indication of the location of the shop system and searching for available compartments within a specific range around that location. Moreover, claim 8 defines that the system uses the IP address of the shop system to identify its location automatically.
The main difference of the claimed system from the system of D1 is that in the latter the location is input by the user, who makes the reservation request (paragraph [158]), while in the claimed system the user’s location (“shop location”) is identified automatically by the system on the basis of the IP address of the shop’s terminal.
However, the Board considered that the difference refers to a mere automation of a manual process and thus does not involve an inventive step:
3.5 The board does not find these arguments persuasive. Leaving open the question of whether minimising the user interaction with the system represents a technical problem, the board notes that automating steps of a manual process has always been considered a pervasive aim in any technical system.
3.5.1 The board thus considers that the skilled person would inherently seek to automate any step in the compartment reservation procedure described in D1. One of the few user inputs in the reservation procedure is the input of the desired location. It would thus be obvious for the skilled person to try and automate this step of the procedure, i.e. to provide for an automatic identification of the user’s location.
Since none of other requests were considered allowable, the Board dismissed the appeal and the European patent application was ultimately rejected.
More information
You can read the whole decision here: decision T 1203/20 of January 25, 2024 of Technical Board of Appeal 3.4.03.