Board of Appeal of the European Patent Office T 931/95, commonly known as Pension Benefit Systems Partnership, is a decision of a Technical Board of Appeal of the European Patent Office (EPO), issued on September 8, 2000.
It stated that having a technical character is an implicit requirement of the EPC to be met by an invention in order to be patentable.
[5] In contrast, regarding an apparatus claim, the Board stated that a computer system suitably programmed for use in a particular field, even if that is the field of business and economy, has the character of a concrete apparatus in the sense of a physical entity, man-made for a utilitarian purpose and is thus an invention within the meaning of Article 52(1) EPC.
The recent decision T 258/03 does not make this distinction between method and apparatus claims anymore.
52 EPC requirement, the claim was eventually considered to lack inventive step.