Section 1(2) and Article 52(2)(c)EPC exclude business methods
“as such”... but-
▪ In Vicom, the EPO stated that to be patentable, a business
method requires a technical contribution.
▪ In Merrill Lynch, the UK patent office held that it requires a new
technical result.
▪ In PBS, the EPO disapproved of the contribution approach and
held that it was more appropriate to proceed to the question of
inventive step and novelty before considering the question of
technical character.
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