T 2052/12 - Smart card repayment limit inventive

Key points

• The Board finds a claim inventive directed to a payment method. 
• The invention deals essentially with parking meters that can credit money on smart cards, in order to make repayments to the smart card. Such parking meters are stolen which were thus able to credit money " to any smart cards as wished" 
• In the invention, this is addressed (in essence) by storing a repayment limit on the smart card and accepting credits only up to that amount. The repayment limit is set equal to the (outstanding) debited amount of a debit (i.e. payment with the card).  The Board finds this technical and inventive. 

EPO T 2052/12 -  link

IV. The wording of independent claims 1 and 4 of the main request is as follows:

"1. A payment method (BV) executed by a communication facility (1, 2, N) and at least one data carrier (11, 12, K) for debiting a payment value unit (BW) from the data carrier (11, 12, K), in order to pay for a performed service, wherein the following steps are executed:
debit from a memory value unit (SW) stored in the data carrier (11, 12, K), of a debit value unit (AW) sufficient for payment for the maximum service to be performed, wherein a repayment limit (RL) stored in the data carrier (11, 12, K) is set, by the data carrier, to the amount of the debited debit value unit (AW);
calculation of a credit value unit (AWE) to be credited back, wherein the payment value unit (BW) to be paid for the actually performed service is subtracted from the debited debit value unit (AW);
check, by the data carrier (11, 12, K), whether the credit value unit (AWE) to be credited does not exceed the stored repayment limit (RL), wherein only when it is detected that the credit value unit (AWE) to be credited does not exceed the stored repayment limit (RL), the credit value unit (AWE) is credited by adding the credit value unit (AWE) to the memory value unit (SW) stored in the data carrier (11, 12, K), wherein after the crediting of the credit value unit (AWE) to the data carrier (11, 12, K) the repayment limit (RL) stored in the data carrier (11, 12, K) is reduced by at least the credited credit value unit (AWE), and wherein before the crediting of the credit value unit (AWE) to the data carrier (11, 12, K), key information (SI1, SI2) output by the communication facility (1, 2, N) and identifying the communication facility's credit authorization is checked by the data carrier (11, 12, K), and wherein the communication facility (1, 2, 8, N) is authorized to credit the credit value unit (AWE) up to at most the value of a maximum credit limit (ML) if the communication facility (8) has a first credit authorization, and wherein the communication facility (1, 2, N) is authorized to credit the credit value unit (AWE) up to at most the value of the repayment limit (RL) stored in the data carrier (11, 12, K) if the communication facility (1, 2, N) has a second credit authorization."

1.3.2 The board agrees with the examining division in that a reimbursement value and a repayment limit are financial concepts and can thus be considered as part of a scheme of doing business. As such these are therefore non-technical features.

On the other hand, the contribution of the claimed method over the closest state of the art document D2 involves tech­nical features carried out by the data carrier, in particular the storing, setting and reducing of the repayment limit, the checking of the reimbursement value and its contin­gent addition to the memory value, and the checking of key information identifying the communica­tion facil­ity's credit authorization.

Under such circumstances it has to be considered whether these technical features bring about any tech­nical advan­tages or effects beyond the mere implementa­tion of the claimed method in such a way as to achieve the aims corresponding to the non-technical features (see Case Law of the Boards of Appeal of the EPO, 8th edition 2016, sections I.D.9.1.3 and 9.1.4).

[...]

 Therefore, ­the technical effect of improving the claimed payment method by lowering the security risk due to theft of certain secret key information is considered to be credibly achieved by the distin­guishing features over the closest state of the art document D2.

The objective technical problem to be solved by the invention is therefore to achieve this technical effect.

[...]

Accordingly, the subject-matter of claims 1 to 9 of the main request involves an inventive step (Article 52(1) EPC and Article 56 EPC 1973).