d) Payment not from own account 

In T 186/22 the board held that the appeal fee having been debited not from the patent proprietor's account but from that of a third party could not alter the fact that the requirement of Art. 108, second sentence, EPC being fulfilled. That provision did not require the payment of the appeal fee to be made by the appellant. In fact, the question of who paid the appeal fee was irrelevant to whether the appeal was deemed to have been filed. It was sufficient that an appeal fee be paid (in the appropriate amount) before the expiry of the appeal period.