triggering (1102) the reminder of the action item based on the two or more reminder conditions when conditions corresponding to the two or more reminder conditions are determined to exist, wherein a visual, audible or vibratory reminder is generated on the electronic device (201) when the reminder is triggered,

In relation with the business constraints the appellant argued that the following two features a) and b) defined in claim 1 were technical and should not be part of the formulation of the administrative business scheme: The Case Law of the Boards of Appeal of the European Patent Office is a book, published by the European Patent Office (EPO), which summarizes the body of case law on the European Patent Convention (EPC) developed by the Boards of Appeal of the EPO since the EPC entered into force at the end of the 1970s. Its tenth edition was published in 2022. [1] The book is also known as the "White Book", [2] and it was reported to be in 2012 the best-selling publication of the EPO. [3] The White Book is published every three to four years. In the meantime, a special edition of the EPO Official Journal is issued each year summarizing the most recent case law of the boards of appeal. [4] Since the result of the straightforward implementation of the above cited business scheme is the method defined in claim 1, the board concludes that the subject-matter of claim 1 of the main request does not involve an inventive step (Articles 52(1) and 56 EPC). The subject-matter of claim 1 comprised a combination of technical and non-technical features. However, it involved an inventive step becauseTherefore, the board concludes that the amendments of claim 1 of the third auxiliary request represent a "fresh case". Claim 1 was amended compared to claim 1 of the main request by adding after the "receiving" step and prior to the "obtaining" step the following wording: When starting from a notorious computer system, like a PDA, the business person provides the following purely administrative/business scheme as business constraints to the technically skilled person for implementation on the notorious computer system: The argument that the appellant, in response to the telephone conversation, wanted to react to the examining division's decision in a calm and reflected manner without any time pressure is also not convincing. On the one hand, if the appellant/applicant had attended the oral proceedings, it would have had the opportunity to file this request, whereby the available time would have been considered sufficient. On the other hand, even prior to the telephone conversation the appellant/applicant could have considered exactly which request(s) it wanted to pursue, since the negative opinion of the examining division was known prior to the above-mentioned telephone conversation. Already in the summons to oral proceedings the examining division indicated its negative opinion with regard to the main request. Therefore, the board concludes that the subject-matter defined in claim 1 of the second auxiliary request does not involve an inventive step (Articles 52(1) and 56 EPC), either.

Claim 1 of the third auxiliary request is based on claim 1 of the main request with the following amendments: receiving (310) a request for creation of an action item (300), the action item (300) comprising a record of proposed future action; wherein the request for creating of the action item (300) is a request to create the action item (300) based on stored content (301) and wherein a reminder of the action item provides access to the stored content (301), wherein the stored content (301) is one of: a video; an audio file; a word-processor document; an electronic book; or an image;A word should be said here about I.D.4.5 in the ‘White Book’, ..." in David Rogers, "Patents: Inventive step (alternative formulation of problem) and ‘old’ closest prior art: whether to admit an auxiliary request filed at the end of the oral proceedings", Journal of Intellectual Property Law & Practice (2007) 2(4): 210-211 doi: 10.1093/jiplp/jpm021 the business person does not provide any technical input but only the above cited business method including only non-technical, administrative constraints and that The technical advantages as argued by the appellant, namely the reduction of wear and tear, the reduction of power consumption and the reduction of time when accessing the stored content are technical advantages which are inevitable side effects of the computer implementation itself. These side effects cannot be considered as further special technical effects since they derive inherently from the computer implementation of the desired business aim.

triggering (1102) a reminder of the action item based on the two or more reminder conditions when conditions corresponding to the two or more reminder conditions are determined to exist, wherein a visual, audible or vibratory reminder is generated on the electronic device (201) when the reminder is triggered, VIII. The appellant's arguments, insofar as they are relevant to the present decision, may be summarised as follows:receiving a request for creation of an action item, the action item concerning proposed future action of a user; II. At the end of the oral proceedings before the board the appellant requested that the decision under appeal be set aside and a patent be granted on one of the main request or first to third auxiliary requests, all submitted with the statement setting out the grounds of appeal. The main request and the first and second auxiliary requests are identical to the corresponding requests underlying the impugned decision. wherein the request for creating of the action item (300) is a request to create the action item (300) based on stored content (301) and wherein a reminder of the action item provides access to the stored content (301), wherein the stored content (301) is one of: a video; an audio file; a word-processor document; an electronic book; or an image;" The third auxiliary request was submitted for the first time with the statement setting out the grounds of appeal. The board therefore has the discretion not to admit this request into the proceedings under Article 12(4) RPBA 2007 (which here applies according to Article 25(2) RPBA 2020), if it considers that it could and should have been filed during the first instance proceedings. This business constraint is clearly not of a technical nature and falls within the normal realm of a business person, who has no technical knowledge. Contrary to the appellant's doubts, the board does not consider the possible technical knowledge of a notional business person to be relevant for the present case, because the technical parts are notorious or obvious to the technically skilled person.

The board is of the opinion that these amendments do not to change the non-technical nature of the underlying problem nor do they provide any further technical effect. These newly introduced features represent further non-technical business constraints of the underlying administrative/business method. They are handed over to the skilled person, who implements them in a straightforward manner without any difficulty. As to the appellant's argument in this regard, the board notes that the automatic determination of the "identification" of appointments, communications or planned travel are inherent side effects of the computer implementation and automation of the process. This automation is not considered as a further special technical effect that may establish inventive step. It is a foreseeable effect of the computer implementation of the underlying business constraint. writing in the period up to the end of 2021, as well as a number of particularly important ones from the first All these features as such are individually known and are also known as being, if necessary, integrated in a notorious computer system. This represents the technically skilled person's notorious knowledge. Although no documentary evidence is necessary for notorious knowledge, D4 and D5 are cited in this context as examples of such devices. This notorious knowledge represents the starting point for assessing inventive step. Therefore, for assessing inventive step the board starts from a processor of an electronic device configured to receive and process information, the device being adapted to generate visual, audible or vibratory reminders and also including a location sensor, as for example a personal digital assistant (PDA).Therefore, in view of the above the board decides not to admit the third auxiliary request into the appeal procedure (Article 12(4) RPBA 2007). The further definitions of the identifying step as defined in claim 1 of this request related to the technical improvement of the functionality of the electronic device. It was not rendered obvious by the available state of the art and was therefore inventive. I. The appeal is against the decision of the examining division to refuse European patent application No. 12 174 629 on the grounds that the subject-matter defined in the independent claims of the then main request and the then first and second auxiliary requests did not involve an inventive step (Article 52(1) EPC in combination with Article 56 EPC). Josefsson, Carl (11 August 2022). "The tenth edition of the "Case Law of the Boards of Appeal of the EPO" is now available online". www.epo.org. Haar: European Patent Office . Retrieved 12 August 2022.