T 1438/24 (Two-array LED display/PHILIP MORRIS PRODUCTS) vom 16.04.2026

Claim construction in light of G1/24 - narrow claim interpretation based on description and drawings (no - not accepted)
Inventive step - simultaneous display of different technical states of an e-cigarette instead of displaying them at different times (no - not technical)
Inventive step - display layout with a first annular area surrounding a second area (no - not technical)

[T]he automatic provision of visual indications of conditions prevailing in a technical apparatus may, in principle, produce a technical effect [...].
... The actual difference between claim 1 and D1 resides solely in the decision to present different technical conditions simultaneously. This does not provide the user with any additional insight into the internal operation of the device beyond what is already disclosed in D1. Rather, it merely concerns the manner in which information already available in D1 is presented to the user.
While it may be accepted that the simultaneous presentation of multiple items of technical information may be perceived by some users as clearer or more practical, other users may regard such a presentation cluttered or less legible and may prefer the one-at-a-time presentation of D1. Be it as it may, according to the established case law, effects such as improved clarity of presentation or reduced cognitive burden, which merely reflect subjective user preferences, do not constitute technical effects and therefore cannot contribute to an inventive step [...].
(See point 2.16 of the reasons)