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. At the time, it was a landmark decision for interpreting Article 52(1) and (2) of the European Patent Convention (EPC) but has now largely been superseded by the decisions in T 641/00 (Comvik, Two identities) and T 258/03 (Hitachi, Auction Method).
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. In other words, the technical character requirement is inherent to the notion "invention" in Article 52(1). It also confirmed that methods only involving economic concepts and practices of doing business, or methods for doing business as such, are not inventions within the meaning of Article 52(1) EPC, and are therefore not patentable.
Back in 2001, decision T 931/95, along with decision T 769/92 ("Sohei case"), were considered the most relevant cases from the EPO Boards of Appeal regarding business methods.
Read more about T 931/95: Decision