c) Database management systems and information retrieval systems 

In T 107/87 the board held that a data coding rule for identifying and eliminating statistical redundancy contributed to the solution of a technical problem where it was used to reduce the amount of data to be stored or transmitted. This meant that if a computer-implemented method included steps of losslessly compressing and decompressing intermediate results to reduce the amount of memory space required for storing those results, at least those steps would make a technical contribution. The implementation of the coding rule would normally still be algorithmic in nature (see also T 650/13).

In T 1242/04 (OJ 2007, 421) the invention related to a system for providing product-specific data in a service station. Since the claims featured a central database for recording the required status and an archive store for recording the actual status which communicated with each other by computing means, the board found that they had technical character.

In T 1924/17 the board saw no reason why relational database management systems should be non-technical, if it was accepted that database management systems in general were technical. The board noted that its position was not that all features implemented in (relational) database management systems contributed by virtue of this fact alone and independent of their nature to the technical character of an invention. The board reviewed decisions relating to accessing data base management systems (T 1242/04 (OJ  2007, 421), T 279/05, T 862/05, T 658/06, T 1500/08, T 963/09, T 104/12, T 1965/11) and information retrieval (T 1569/05, T 1316/09, T 309/10, T 2230/10, T 598/14). In the light of these decisions, the board in T 1924/17 summarised that structured declarative queries, which are used for retrieving data managed in a relational database management system, normally have precise, formally defined semantics and the database management system then retrieves the specified data set as a result. It explained that relational database management systems typically executed such queries by determining an efficient query execution plan based on cost estimates for the necessary internal operations of the computer system. Such database management systems were software platforms for the centralised control of data. Features of these platforms often had a technical character, as they had been designed based on engineering considerations concerning the efficient exploitation of the computer system as a technical system. Information retrieval systems typically had to formally calculate a semantic similarity of documents, which is typically regarded as involving non-technical considerations and being based on subjective criteria and the content (semantics) of the documents to be retrieved (see also T 598/14, T 2401/22).

In T 279/05 the invention related to determining airline seat availability. The invention involved a mixture of technical aspects, e.g. servers, and non-technical aspects, e.g. airline seat availability and yield management. Database querying was considered be a technical field by the board.

In T 2852/19 the invention related to optimising the occupancy of an event. The aim was to avoid seats remaining empty if visitors could not reach the event location in time. The invention proposed to automatically determine whether visitors to an event were in a defined area at a certain distance from the venue. GPS data from visitors' cell phones was used for this purpose. If ticket buyers were not in said area shortly before the start of the event, an alert was sent to them, and their ticket was resold in case of cancellation.

The board held that there were two effects: (i) was optimising the seat occupancy, which was held to be technical; and (ii) was to increase the profit by reselling seats shortly prior to the event in case a visitor had cancelled its venue, which was held to be non-technical. The board found that T 279/05 did not apply since the dynamic adjustment of the monitored area had already been disclosed in the prior art. See also T 2879/18.

In T 697/17 the board stated that in decision T 388/04 (OJ 2007, 16), subject-matter or activities that are excluded from patentability under Art. 52(2) EPC and Art. 52(3) EPC were considered "to remain so even where they impl[ied] the possibility of making use of unspecified technical means" (point 3 of the Reasons). But that was not the case where the claimed subject-matter does not only merely "imply the possibility of making use of unspecified technical means" but in fact clearly implied the use of concrete technical means. For example, in decision T 650/13 the board considered that the method of claim 1 was not excluded because "transmitting the symbol in a code word to a decoder" implied the use of technical means (point 6.1 of the Reasons). In T 697/17, the board held that carrying out a method performed in a relational database system involved the use of a computer system. Therefore, the claimed method could not be seen as a purely abstract method, but as a method which used technical means. The board furthermore noted that there were several examples in the case law in which features of a database system had been considered as technical aspects when assessing inventive step (T 1242/04, T 1025/08, T 1500/08, T 1414/10, T 1924/17). In this context, the board noted that describing a technical feature at a high level of abstraction did not necessarily take away the feature's technical character.

In T 1272/20 the board agreed with the appellant that T 598/14 did not express that any manner in which a computer performs a search was non-technical for the sole reason that the result was a "better search". The board did not agree with the examining division that only the "physical features" of the claim, or that only the features "computer-implemented", "database" and "links", made a technical contribution within the context of claim 1. The claim specified a computer-implemented method for searching personal information when a user performs an internet search. The claimed method involved retrieving data from the internet and from a separate database, the "personal database", and presenting to the user search results and links to access some of those search results. It also included steps describing a user interaction with the computer system: receiving a user selection of one of the links and retrieving the respective data. These features contributed to the technical effect of retrieving data in a computer system. One technical constraint was that the notes were stored in a personal database which could not be searched by the search engine. Even though, the decision to present only previews of the notes, instead of the full notes, was not technical, technical considerations were involved Links were considered technical in the decision under appeal. The mere fact that at least some of these technical features might have been notoriously known or generically specified, or that some technical aspects might have been implicit from the claim, did not mean that the corresponding subject-matter cannot make any technical contribution. Relevant was whether the criteria developed by the case law were fulfilled.

In T 873/19 the board was of the opinion that reducing the number of multiple tables needed to be processed when retrieving the attributes for a given BOI is a technical effect.

In T 366/20 the application related to devices and methods for managing the identity of media content data. The appellant had argued that the objective technical problem to be solved was "how to provide, at a client node, a more efficient non-duplicate downloading and file identity reconciliation". The board stated that claim 1 did not define how the "first master identifier" received from a server node corresponded to the "first set of metadata" provided by the client to this server node. Since the first master identifier seemed to be determined based only on the metadata, and since the metadata may be incomplete or incorrect or otherwise not identifying for the media content or may not capture differences in actual content of the media content data files (for example due to different versions of the same song, movie etc.) the result of the claimed method seemed to be essentially unpredictable with respect to the detection of duplicate media content files over the whole scope of the claim. Moreover, the claim did not define what "processing" was performed on the first master identifier to identify whether a second master identifier was stored in the database of local identification data and metadata that matched the first master identifier. Since there was no technical effect over the whole scope of the claim, no technical problem was solved over the whole scope of the claim and the claimed method therefore lacked an inventive step.