In the interview, President Battistelli characterizes DG3 as an administrative unit of the EPO, composed mainly of EPO examiners. He tells us that the EPC Member States deliberately chose not to create a judiciary body under the EPC but, rather, a mere administrative unit of the EPO.
Is this what the AC now thinks? Does this explain the unseemly rush to bury DG3? Has the thought taken root, at AC level, that all of the 38 EPC Member States are failing, still, even after more than 40 years of trying, to comply with GATT-TRIPS?
I don't understand. I thought it was well settled, that DG3 is a judicial not an administrative instance. Is the EPO President so almighty that he can by fiat declare DG3 to be administrative and NOT judicial?
Or is all this just a manifestation of the pan-European political imperative, to jump start the UPC?
Being an Ena-teque, I suspect BB sees everything as an administrative task with technical/judicial support functionaries. That reflects his treatment of staff in general. DG4 (HR et al) is the core and DGs 1 and 3 are support acts for the successful operation of DG4. While HR, IT etc. were previously the support, the system has changed and now examining and boards of appeal are downgraded to simple tasks which any non-ENA person can do.
The President€´s public statement that the Boards of appeal are an administrative and non-independent unit of the office amounts to a complete reversal of the position which had been successfully maintained for more than 40 years and had been absolutely paramount to the recognition of the European Patent System by national jurisdictions. This is indeed a disastrous move, which might have dramatic consequences. It looks as if the President, after having been discharged by the AC at its last meeting of any further responsability in the necessary institutional reorganisation of the Boards, had in his rage decided to broke the toy altogether. And beyond the Boards, it is now the AC which he attacks.
A short summary of the managing ip interview is here: Battistelli defiant in interview about EPO reforms The part about the BOAs only forming an administrative unit is not included.
BB suggests that the appeal fee should cover 20-25% of the cost instead of 4% as is the case now. (A similar if not much larger increase of the opposition fee is not difficult to predict. To justify such increases one only needs to compare with the UPC fees!)
BB says it is "short-sighted" to suggest the backlog of appeal cases has been created in the past few months due to positions being vacant ("few" being 18). Yet another sign of intellectual dishonesty, as no one has suggested that the recruitment stop has created the backlog. The backlog was there already, but how is that an excuse for stopping recruitment.
BB appears to be not completely unwilling to make new nominations next year. We'll have to wait and see what kind of surprise he has in mind.
BB still wants to move the BOAs out of his sight and to prevent BOA members from working in private practice after leaving their position. How is he going to do that, now that the AC is said to have taken the reform out of his hands? But of course he still controls whoever will draft the new proposal.
Battistelli seems to want be BoA to be self-financing and yet they are only an administrative organ rather than a judicial body. Will HR be equally self-financing? And, if so, how? Make your mind up!
Is sing members - 18 now but how many after end of year retirements? New nominations? But no posts have been advertised for more than a year. There can't be anybody ready beyond personal nomination by him? Preventing from working by attacking their pension (rights)? Delaying payment of final allowances? Going to court - a single case would frighten a few? Playing hard ball with their new employers? You think he wouldn't be creative?? (See you at the ILO in 10 years...)
We understand that you and the Administrative Council believe that the efficiency of the Board needs to increase, and the independence needs to be assured. Can you reassure people about that in the long-term but also in the short term, given concerns about the number of members of the Boards?
[Battistelli:] The first thing to bear in mind is that when the EPC was discussed, signed and ratified the member states decided not to create a judiciary body that would be separate from the EPO. They decided to create an administrative unit within the EPO with the task of reviewing EPO decisions on granting or not granting a patent. It is recognised there is some ambiguity there but this was the choice made at the time. There have been several attempts over the past 40 years to change the situation, and they have never succeeded.
So the situation is we have an administrative unit, composed mainly of former patent examiners, who are independent in the decisions they make but not in their legal nature.
In spite of the ambiguity during the past 40 years, the Boards of Appeal have built strong reputations for independence and expertise and have fulfilled their roles to everybody's satisfaction.
Second, on independence, this has never been questioned. None of my predecessors or myself have interfered in any specific case. But there was a decision of the EBA [R2/14] that said because of the links there was a risk of partiality.
This decision obliged us to reconsider the links between the Boards of Appeal in general and the Office, so we started to reflect on a situation where we could increase the independence and the efficiency. I made some proposals to the Council, one of them to create a fully separate organisation, but this would imply a change to the EPC. The Council clearly indicated they cannot consider this option and asked me to make some proposals within the framework of the EPC.
It's not easy because the EPC clearly gives the responsibility for the management of the Boards to the president of the Office. How can the president delegate this authority to someone else? We looked at creating a person with a new function of president of the Boards of Appeal, who would be the highest authority but also in charge of administration, like in many national courts. Somebody has to manage the Boards, and it cannot be the president of the Office as this would be understood as interference in their functioning. It's legally not easy because it has to be compliant with the EPC.
We are also proposing to help the Council fulfil its duties by creating a subsidiary body composed of members of the Council and high level judicial people. This body will be consultative and will help the Council to fulfil its duties for the Boards of Appeal.
I'm confident that we could make some proposals in the first months of 2016 in order to go forward.
BB's interpretation is not consistent with what is recorded in the Travaux Preparatoires: http://webserv.epo.org/projects/babylon/tpepc73.nsf/0/4ADD77A7756D6D23C125742700497086/$File/Art23eTPEPC1973.pdf
Quick ! Make a backup copy before they disappear online ...
[PDF]
. The document is dated 30th of September, 1973 (nearly a decade before I was even born). Having paged through it, I'm increasingly convinced it's quite valuable in the sense that it enables detailed comparison between the original goals, rules and visions of the EPC to what Battistelli now claims them to be (revisionism). It's not necessarily the EPC that's misguided; it's those who misinterpret or distort its message (or find loopholes) that put it to shame. ⬆
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* Large multinational corporations' actually, as the infamous new pattern serves to show.