T 2043/23 (Resistance-based temperature monitoring/PHILIP MORRIS PRODUCTS) vom 12.05.2026

Application of G 1/24 - explanatory, non scope-altering, use of the description (yes - in line with G 1/24)
Inventive step - using measured heater's resistance at room temperature for further calculations (no
Inventive step - obvious)
Inventive step - monitoring whether the heater's resistance reaches a threshold value outside of an expected time period (yes
Inventive step - no hint in prior art)

[T]he Board notes that the present case differs from situations such as that in decision T 439/22 (reasons, points 2.4, 3.4 and 6), in which the description and drawings were relied upon to broaden the scope of a claim beyond what was conveyed by the claim wording read in isolation.
Here, by contrast, the description served an explanatory and confirmatory function by assisting the skilled reader in recognising an embodiment already encompassed by the claim wording, without altering the scope of the claim.
This modest explanatory and confirmatory use of the description is consistent with the principles set out in G 1/24 (see T 2027/23 - Turnable ladder/IVECO, reasons, point 3.5.2).
(See points 2.9 and 2.10 of the reasons)