T 1081/09 (Component management system/RICOH) of 26.5.2014

Summary of Facts and Submissions

I. The appeal is against the decision of the examining division to refuse European patent application No. 01116761.6, entitled "Component management system and method", for lack of inventive step (Article 56 EPC 1973).

II. The examining division cited the following documents:

D1: WO-A-98/49664, "Vehicle speed limit enforcement device";

D2: US-A-5 319 542, "System for ordering items using an electronic catalogue".

Setting out from a general purpose computer system, the examining division noted that managing component information was a business related aim concerning administrative aspects of procurement. While the implementation was of a technical nature, it was straightforward to a skilled person using standard programming techniques. The information managed had a cognitive (commercial) meaning and entailed no surprising functional interaction with the general purpose computer. Documents D1 and D2 were only cited as illustrative evidence to show that similar administration methods had been implemented as software for computer systems.

III. In its notice of appeal, the appellant requested that the refusal decision be set aside. Oral proceedings were requested on an auxiliary basis.

The statement setting out the grounds of appeal upheld the refused claims (claims 1 to 22 filed on 10 February 2004) as a main request and included two amended sets of claims as first and second auxiliary requests. The Board takes the appellant's request to be that a patent be granted on the basis of one of these sets of claims.

(a) System claim 1 according to the main request reads:

"1. A component management system comprising:

a component database (119) which registers component;

receiving means (15) which receives information regarding a plurality of components;

component-data updating means (114) which updates the component data registered in the component database (119); and

selection means (12, 13) which selects an arbitrary component from a plurality of components registered in the component database;

characterized in that

said component database (119) stores information regarding a plurality of components in association with examination results of the plurality of components;

said receiving means (15) receives improvement/cessation information regarding a component; and

component-data updating means (114) updates the component data based on the improvement/cessation information received by said receiving means (15)."

(b) The 1st auxiliary request appends the following paragraph to claim 1 of the main request:

"[...], wherein

the component data includes a recommendation to use a component based on the examination results."

(c) The 2nd auxiliary request appends the following paragraph to claim 1 of the main request:

"[...], wherein

the component data includes a rating of a component determined by examination;

the component is examined based on the component data received by said receiving means; and

said component data updating means (114) includes

registration means which registers, in the component database (119), the component data regarding the plurality of components, which has been examined, and

means which adjusts a rating of each of the plurality of components in accordance with re-examination results based on the information received by said receiving means."

IV. The arguments submitted in the statement setting out the grounds of appeal can be summarised as follows.

Main Request

The system according to claim 1 seeks to enable departments of a corporation to collectively manage information regarding components, and to enable a product designer or manufacturer to easily select a high quality component. This goal is achieved by the following features:

a) The database stores information regarding components in association with examination results concerning the components;

b) the component-data updating means updates the database based on improvement/cessation information regarding an admitted component;

c) the database can be accessed by a designer or a manufacturer on-line.

According to D1, only items that have been approved for purchase are registered in a product database (D1, page 17, line 2; page 17, line 18). Document D2 does not disclose any criterion on which its catalogue data is based. Thus, the object and effect of the present invention are different from those of documents D1 and D2. The present invention has a technical feature that is not disclosed in documents D1 and D2.

Furthermore, the "improvement/cessation information" and the updating process allow for a more effective use of the claimed component management system: The information that the manufacture of a component has ceased allows for a more effective selection of a component. In case of component improvements, the status of a component may be changed from "non-recommended" to "admitted".

1st Auxiliary Request

The component data includes a recommendation to use a component based on the examination results. Therefore, even if the product designers or manufacturers have different levels of skill, they are able to select a high quality component.

2nd Auxiliary Request

A rating of a component is determined by examination and adjusted in accordance with the result of a re-examination. This allows product designers or manufacturers of any skill level to select high quality components based on recent evaluations.

The adjustment of a rating represents a technical response to received information. Therefore, the claimed system has technical character, is novel and involves an inventive step.

V. In the annex to a summons to oral proceedings, the Board communicated its preliminary opinion that the system of claim 1 (all requests) did not appear to involve any non-obvious technical contribution over a generic computerised database.

VI. In response to the Board's summons, the appellant's representative declared that neither he nor the appellant would attend the oral proceedings. The request for oral proceedings was withdrawn and a decision according to the state of the file was requested.

The Board then cancelled the oral proceedings.

Reasons for the Decision

1. The application

The application was published as

A2: EP-A2-1 182 596.

The management system/method according to the application supports departments of a corporation in selecting and purchasing components (A2, paragraph 0003). In order to provide clear and objective selection criteria (A2, paragraph 0004), an updateable component database stores not only information identifying components but also evaluations of the components ("examination results", original claim 1). The admissibility of a component or a recommendation to use the component may depend on the examination results included in the component database (original claims 2 to 4). A component rating may be adjusted in accordance with re-examination results (original claims 5 and 6).

Main request

Article 56 EPC 1973 - Inventive step

2. In the light of Article 52(1)(2)(3) EPC, Article 56 EPC 1973 requires a non-obvious technical contribution (see e.g. T 641/00-Two identities/COMVIK, Headnote 1, OJ EPO 2003, 352; T 1784/06-Classification method/COMPTEL).

3. The Board concurs with the examining division in considering a generic computerised database as the closest prior art.

4. Making a component database available to a plurality of departments, product designers and/or manufacturers is a choice of corporate policy not requiring any inventive step on the technical implementation level. The fact that the data items designate product components does not have any technical implication for the functioning of the database.

5. Enlarging the component database so that it can be populated with additional useful component information (examination results) does not involve any non-obvious technical consideration, either. The kind of additional information considered useful relates to cognitive content; nor is the problem of different skill levels technical. On the technical implementation level, extending a data set by an additional data field does not require an inventive step. This assessment is confirmed implicitly by the application which leaves implementation details to the skilled reader.

6. Therefore, the Board does not identify any non-obvious technical contribution in system claim 1 of the main request. It follows that an inventive step cannot be acknowledged (Article 56 EPC 1973).

1st Auxiliary request

7. The "recommendation" added to the data concerning a component again constitutes a cognitive aspect which does not have any non-obvious implication for the technical functioning of the database.

2nd Auxiliary request

8. As the "rating" of a component is "determined by examination", it may be one of the examination results already mentioned in claim 1. In any event, it is an obvious desire to update component data and to adjust a rating whenever a re-examination has taken place and more recent information has become available. The technical implementation requires only normal database operations.

9. Therefore, the substantive assessment of the first and second auxiliary requests is the same as that of the main request.

Order

For these reasons it is decided that:

The appeal is dismissed.