T 0064/16 - Considerations that are typical for a graphical designer

Key points

• " Claim 1 relates to a computer-implemented method for navigating modelled objects and relations between the objects that are stored in a relational database of a [ "product lifecycle management" ] PLM system."
• " Features (d), (e), (f) and (g) specify how the objects returned by a navigation step are presented to the user. They therefore relate to a presentation of information, which contributes to inventive step only to the extent that it interacts with the technical features of the claim to achieve a technical effect."
• The Board is not convinced. Even if it were accepted that the claimed disk layout distinguishes itself from arbitrary layouts by achieving a particularly compact display of information, this effect would be the result not of technical considerations, but of considerations that are typical for a graphical designer. It would therefore not be a technical effect but rather an effect that is inherent in the presentation of information (see decisions [...] T 817/16 of 10 January 2019,  [ Document scoring/GOOGLE] reasons 3.12 ).
• There was also a discussion about the meaning of the closest prior art. The Board: "Hence, the existence of document D3 cannot invalidate document D1 as a suitable starting point for assessing inventive step." 

EPO T 0064/16 -  link

3. The invention as defined by claim 1

3.1 Claim 1 relates to a computer-implemented method for navigating modelled objects and relations between the objects that are stored in a relational database of a [ "product lifecycle management" ] PLM system. 

The claimed method includes steps that essentially describe two steps of navigation.

3.2 In the first navigation step, the user selects a first object, a first relation and a first layout.

[...]

3.4 The claim specifies that the selected first and second layouts are a "circular layout, with objects represented in exploded perspective distributed on a disk" and that "the disk links objects which belong to a same level in the hierarchy, and the intersection of two disks defines a cue representative of a hierarchy of the displayed object and its displayed descendants in the hierarchy".

4. Inventive step - Article 56 EPC

4.1 Document D1 discloses an information management system comprising a database which contains types of products, attributes associated with these products, and the processes that govern their lifecycles (page 5, lines 1 to 6 and 26 to 32), which thus falls within the scope of the term "product lifecycle management system". Document D1 is therefore a suitable starting point for assessing inventive step.

In the Board's view, the problem-and-solution approach does not require a selection of the "most promising" springboard to the exclusion of any other document. The claimed invention lacks inventive step within the meaning of Article 56 EPC if the skilled person, starting from some item of prior art, would have arrived at something falling within the terms of the claim in an obvious manner. In practice, it makes sense to limit this investigation to prior-art items that are at least "promising" in that potentially a realistic path exists from the prior-art item towards the invention. In many cases, only one "closest" prior-art item needs to be considered because all other available documents are objectively further removed from the invention [...]

Hence, the existence of document D3 cannot invalidate document D1 as a suitable starting point for assessing inventive step.

[...]

4.7 Hence, the subject-matter of claim 1 differs from what is disclosed in document D1 in that:

(a) the database is a relational database;
(b) two consecutive navigation steps are performed (from a selected first object to second objects and from a selected second object to third objects);
(c) navigation is based on a selected relation;
(d) each navigation step leads to the selected object being "replaced" in the graphical user interface with the set of objects to which it is connected via the selected relation;
(e) the various second and third objects are displayed as 3D representations "in 3D space" according to selected first and second layouts and distributed over the layouts on the basis of the number of the displayed "descendants" in "the hierarchy" (the objects' "relative weights");
(f) the selected first and second layouts are a circular layout, with objects represented in exploded perspective distributed on a disk;
(g) after selecting a circular layout, the disk links objects which belong to a same level in the hierarchy, and the intersection of two disks defines a cue representative of a hierarchy of the displayed object and its displayed descendants in the hierarchy;
(h) the disk is configured to be rotated, independently of any other disk, upon user interaction.

[...]

4.12 Features (d), (e), (f) and (g) specify how the objects returned by a navigation step are presented to the user. They therefore relate to a presentation of information, which contributes to inventive step only to the extent that it interacts with the technical features of the claim to achieve a technical effect.

4.13 In this respect, the appellant argued that the claimed layouts, in particular the disk layout, allowed restraining the display of representations to a delimited screen area. This introduced "a management of the locations of representations on the display device", which was technical as such. The layouts also reduced mouse travel during the navigation process.

The Board is not convinced. Even if it were accepted that the claimed disk layout distinguishes itself from arbitrary layouts by achieving a particularly compact display of information, this effect would be the result not of technical considerations, but of considerations that are typical for a graphical designer. It would therefore not be a technical effect but rather an effect that is inherent in the presentation of information (see decisions T 1543/06 of 29 June 2007, reasons 2.7 and 2.8; T 1214/09 of 18 July 2014, reasons 4.8.8; T 1562/11 of 3 June 2015, reasons 2.5; T 817/16 of 10 January 2019, reasons 3.12). And the alleged reduction in mouse travel is merely the expected result of the compact display of information.