Zusammenfassung von EPC2000 Art 056 für die Entscheidung T0297/20 vom 17.01.2023

In T 297/20 the board held that the mere change, by an operator, of the degree of abstraction of a graphical view ("condensation") of a power grid did not credibly assist a user in performing a technical task by means of a continued and/or guided human- machine interaction process within the meaning of T 336/14 and T 1802/13 and thus could not bring about a technical effect. The application at hand concerned the presentation of information on a visual display regarding control stations and power lines of a power grid for a "Supervisory Control And Data Acquisition" (SCADA) system. Such a system was typically used for supervising, monitoring and controlling a large and complex power grid. Overviews of such grids on screen can render it difficult for an operator to see "the big picture". The invention in question tried to address this by controlling the level or degree of abstraction with which the control stations and power lines were represented and seeking a balance between the amount and the accuracy of the visually represented information. The board stated that this was not bound to be a technical problem. The board recalled that a feature relating to the presentation of information may only contribute to an inventive step if it brought about an overall technical effect. Within the context of graphical user interfaces, this was the case if the feature credibly assisted the user in performing a technical task by means of a continued and/or guided human- machine interaction process regarding both the type of the information presented, i.e. "what" is presented, and the manner in which it was presented, i.e. "how" it is presented (T 336/14, T 1802/13). The appellant referred to case T 115/85 in support of its argument that giving a visual indication constituted a technical problem. The board, however, held that the situation envisaged in T 115/85 where visual feedback on displayed operation states was provided for enabling a technical system's proper functioning had to be distinguished from the one where the information presented was exclusively aimed at the mental activities of the system user as the final addressee (T 336/14). The information presented in the former situation could be typically seen as "technical information" whereas in the latter situation, the presented information had no technical effect. In the present case, even when construing features in the appellant's favour, the board could not recognise any "continued and/or guided human-machine interaction process" associated with these features, let alone one that would assist the user in carrying out a technical task (i.e. a task with an underlying credible technical effect). This conclusion applied to both the features relating to "what" was presented and to "how" it was presented. Instead, those features all related to subjective factors, such as a user's personal taste or preference about how much detail should actually be presented. Such subjective factors were of a non-technical nature. The board concluded that there was no credible technical effect.