T 0232/14 - Storing ranges in database

 Key points

• This is an appeal about the refusal of a patent application directed to "method for identifying manufactured items in containers". The appeal was filed in 2014, decision 06.10.2020. The decision is given publication code [B]. The claimed method boils down to collecting items each having a unique item number in a container, wherein the container has a container number, and storing in a database the item numbers collected in each container. The distinguishing feature is that ranges of item numbers contained in each container are determined and stored in the database.
• “The invention relates to the identification of specially taxed or branded manufactured items (also called units or cartons, e.g. cigarette cartons), packaged into containers (also called cases). Identification allows products to be authenticated as genuine, tracked and traced, which helps to detect contraband and counterfeit products”. 
• “Conventional identification systems stored an individual record of the identifier for each item in the container together with its associated container identifier (see Table 1). This required a large amount of data storage. The invention essentially replaces the individual records with ones representing any contiguous ranges of identifiers for items packed in a container. Since items are generally packed as they are produced, there are fewer ranges than items and thus fewer records in the database.”

• The Board: “Even if the "determining of ranges of unit identifiers" achieved a technical effect, such as reducing data storage and data bandwidth requirements, it is a matter of routine design for the skilled person, a software programmer or a database expert, based on common general knowledge to store the first and the last element of a list of items, instead of the whole list.”
• However, the Board first judges that the “using ranges of unit identifiers to label a number of (consecutive) unit identifiers of manufactured items is, at the level of generality at which it is claimed, on the business side of the line between technical and non-technical subject-matter”

EPO Headnote


The Board judges that using ranges of unit identifiers to label a number of (consecutive) unit identifiers of manufactured items is, at the level of generality at which it is claimed, on the business side of the line between technical and non-technical subject-matter (see e.g. T 144/11 - Security rating System / SATO MICHIHIRO, points 2.1, and 3.6 to 3.9).(See point 2.5 of the reasons)

The ranges of unit identifiers do have a meaning for the business person. They correspond to batches of units produced on a production line. (See point 2.6 of the reasons)

Even if the "determining of ranges of unit identifiers" achieved a technical effect, such as reducing data storage and data bandwidth requirements, it is a matter of routine design for the skilled person, a software programmer or a database expert, based on common general knowledge to store the first and the last element of a list of items, instead of the whole list. (See point 2.9 of the reasons)

T 0232/14 -  link

decision text omitted.