BL number
Concerning rights in
GB 1420108.1
Hearing Officer
Mr S Brown
Decision date
22 January 2019
Person(s) or Company(s) involved
International Business Machines Corporation
Provisions discussed
PA 1977 Section 1(2)
Excluded fields (refused)
Related Decisions


The application provides a way of detecting the unauthorised bulk transfer of emails from a first network to a second network. It does this by determining an arrival rate for internal emails into one or more accounts within the first network and then undertaking a further determination of emails being sent to an external network. By comparing the arrival and sending rates it is able to identify if mail is being bulk forwarded.

The Hearing Officer applied the reasoning in Aerotel/Macrossan and considered the AT&T/Cvon signposts as modified by HTC v Apple and found that the contribution lay entirely in matter excluded as a program for a computer as such. He also considered the guidance in Merrill Lynch and Halliburton and decided that it was also excluded as a method of doing business.

Full decision O/042/19 PDF document264Kb
Content Reproduced verbatim from the Website of the United Kingdom Intellectual Property Office (UKIPO) as permitted under their Terms of Use.

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