CITE: T0931/95-3.5.1
CMON: September 2000
PLAIN: Pension Benefit Systems Partnership
DEFND: European Patent Office
COURT: Board of Appeal of the European Patent Office
DATE: September 8, 2000
HISTORY:
BESCHWERDEKAMMERN BOARDS OF APPEAL OF CHAMBRES DE RECOURS
DES EUROPAISCHEN THE EUROPEAN PATENT DE L'OFFICE EUROPEEN
PATENTAMTS OFFICE DES BREVETS
Internal distribution code:
(A) [ ] Publication in OJ
(B) [X] To Chairmen and Members
(C) [ ] To Chairmen
D E C I S I O N
of 8 September 2000
Case Number: T 0931/95 - 3.5.1
Application Number: 88302239.4
Publication Number: 0332770
IPC: G06F 15/30
Language of the proceedings: EN
Title of invention:
Improved pension benefits system
Applicant:
Pension Benefit Systems Partnership
Opponent:
-
Headword:
Controlling pension benefits system/PBS PARTNERSHIP
Relevant legal provisions:
EPC Art. 52(1), (2), (2)(c), (3); 56; 84
Guidelines C-IV, 1.1, 1.2, 2.2
Keyword:
"Exclusion from patentability: of schemes, rules and methods for doing
business (yes) - of apparatus constituting a physical entity for carrying
out such method (no)"
Decisions cited:
T 0208/84, T 0769/92, T 1002/92, T 1173/97, T 0935/97
XZB 15/98 (German Federal Court of Justice, BGH)
- 2 -
Headnote:
1. Having technical character is an implicit requirement of the EPC to be
met by an invention in order to be an invention within the meaning of
Article 52(1)EPC. (following decisions T 1173/97 and T 935/97)
2. Methods only involving economic concepts and practices of doing
business are not inventions within the meaning of Article 52(1) EPC.
A feature of a method which concerns the use of technical means for
a purely non-technical purpose and/or for processing purely non-technical
information does not necessarily confer a technical character to such a
method.
3. An apparatus constituting a physical entity or concrete product,
suitable for performing or supporting an economic activity, is an
invention within the meaning of Article 52(1) EPC.
4. There is no basis in the EPC for distinguishing between "new features"
of an invention and features of that invention which are known from the
prior art when examining whether the invention concerned may be considered
to be an invention within the meaning of Article 52(1) EPC. Thus there is
no basis in the EPC for applying this so-called contribution approach for
this purpose. (following decisions T 1173/97 and T 935/97)
Case Number: T 0931/95 - 3.5.1
D E C I S I O N
of the Technical Board of Appeal 3.5.1
of 8 September 2000
Appellant: Pension Benefit Systems Partnership
8740 S.W. 93rd Court
Miami, FLorida 33173 (US)
Representative: Carter, Caroline Ann
ABEL & IMRAY
20 Red Lion Street
London WC1R 4PQ (GB)
Decision under appeal: Decision of the Examining Division of the
European Patent Office posted 7 July 1995
refusing European patent application
No. 88 302 239.4 pursuant to Article 97(1)
EPC.
SUMMARY:
Economic and business methods are not technical and not patentable.
Decision doesn't define 'technical'.
JUDGE:
Composition of the Board:
Chairman: P. K. J. van den Berg
Members: R. R. K. Zimmermann
V. Di Cerbo
- 1 - T 0931/95
DECISION:
Summary of Facts and Submissions
I.
The appeal is directed against a decision of the examining division, posted
on 7 July 1995, refusing European patent application No. 88 302 239.4.
The reason for the refusal was that the application related to a method
for doing business, lacking any technical character and thus being excluded
from patentability under Article 52(2) and (3) EPC. According to the decision
the closest prior art consisted of existing private pension plans as
described at page 1, lines 18 to 24 of the application. It was, however,
not possible to deduce from the application any technical contribution
provided by the claimed subject-matter to the prior art.
More in particular the subject-matter as claimed, considered as a whole,
did not provide any contribution to the art in a field not excluded from
patentability under Article 52(2) EPC ie the application related to
non-patentable subject-matter as such, and here the decision also referred
to Article 52(3) EPC.
Because the features of existing private pension plans were not mentioned
in the application, no objective problem of technical character could be
deduced from the difference between the claimed subject-matter and the
closest prior art. Furthermore the decision under appeal pointed out that
any skills necessary to understand what was realised
- 2 - T 0931/95
by the invention were not of a technical character since the application
dealt with schemes, rules and methods for doing business without any
technical problem being solved.
Apart from the data processing means, the claims of the then main request
contained expressions like average age computing means, life insurance cost
computing means, administrative cost computing means and the claims of the
then auxiliary request mentioned additionally first to fourth mathematical
component means and first to second mathematical product means.
In the decision under appeal these expressions were considered as missing
any technical definitions; said means were considered as hinting only at
their purpose, namely to serve for division of labour taking into account
commercial or managerial considerations and not defining the features of
the technical equipment used; the whole description did not suggest or
indicate any technical considerations.
II.
The appellant filed a notice of appeal on 8 September 1995, requesting
reversal of the first-instance decision. The appeal fee was paid the same
day and a statement setting out the grounds of appeal was filed on
15 November 1995.
With the statement of grounds the appellant submitted a main request,
corresponding, apart from two corrected minor errors, to the main request
as refused by the decision under appeal, a first auxiliary request, and
a second auxiliary request, the latter corresponding to the auxiliary
request as refused by the decision under appeal.
- 3 - T 0931/95
Independent claims 1 and 5 of the main request read as follows:
"1. A method of controlling a pension benefits program by administering
at least one subscriber employer account on behalf of each subscriber
employer's enrolled employees each of whom is to receive periodic
benefits payments, said method comprising:
providing to a data processing means information from each said subscriber
employer defining the number, earnings and ages of all enrolled employees
of the said subscriber employer;
determining the average age of all enrolled employees by average age
computing means;
determining the periodic cost of life insurance for all enrolled employees
of said subscriber employer by life insurance cost computing means; and
estimating all administrative, legal, trustee, and government premium
yearly expenses for said subscriber employer by administrative cost
computing means;
the method producing, in use, information defining each subscriber
employer's periodic monetary contribution to a master trust, the face
amount of a life insurance policy on each enrolled employee's life to be
purchased from a life insurer and assigned to the master trust and to be
maintained in full force and effect until the death of the said employee,
and periodic benefits to be received by each enrolled employee upon death,
disability or retirement."
"5. An apparatus for controlling a pension benefits system comprising:
a data processing means which is arranged to receive information into
a memory from each subscriber employer defining the number, earnings and
ages of all
- 4 - T 0931/95
enrolled employees, said data processing means including a processor which
includes:
A. average age computing means for determining the average age of all
enrolled employees;
B. life insurance cost computing means for determining the periodic cost
of said life insurance for all enrolled employees of said subscriber
employer;
C. administrative cost computing means for estimating all administrative,
legal, trustee, and government premium yearly expenses for said subscriber
employer;
the apparatus being arranged to produce, in use, information defining each
subscriber employer's monetary contribution to a master trust; the face
amount of each life insurance policy to be issued and made payable to said
master trust by a life insurer on the life of each enrolled employee and
to be maintained in full force and effect until the death of the said
employee; and periodic benefits payable by
said master trust to each enrolled employee upon death, disability, or
retirement."
Dependent claim 6 of the main request read as follows:
"6. An apparatus as claimed in claim 5, wherein the processor is arranged
to produce a first mathematical component for estimating the minimum number
of years of benefits liability to a master trust for each said subscriber
employer including reducing the minimum expected age for each enrolled
employer to receive benefits by said average age of enrolled employees
for each subscriber employer;
a second mathematical component for estimating the
future value of all life insurance proceeds from each
of said subscriber employer's enrolled employees;
- 5 - T 0931/95
a third mathematical component for estimating the immediate future assets
of all life insurance policies issued for all enrolled employees for each
said subscriber employer;
a fourth mathematical component for estimating a cash reserve to fund
contingent disability benefits;
a first mathematical product means for computing a predividend component
of each subscriber employer's monetary contribution for said procuring of
a life insurance policy for each enrolled employee including reducing said
second mathematical component by said third mathematical component, then
dividing by said first mathematical component to produce a first dividend
which is then divided by said subscriber employer's periodic payroll; and
a second mathematical product means for computing said subscriber employer's
said periodic monetary contribution including summing said first mathematical
product means, said fourth mathematical component, said periodic cost of
said life insurance, and said expenses."
The only independent claim of the first auxiliary request, claim 1, is
identical with claim 5 of the main request.
The only claim of the second auxiliary request corresponds in substance
to claim 6 of the main request.
III. Oral proceedings before the Board took place on 8 December 1999.
The appellant submitted the following requests:
- 6 - T 0931/95
the decision under appeal be set aside and a patent be granted on the basis
of the main request or the first or second auxiliary requests, all requests
as filed with the statement of grounds;
subsidiarily, the following question of law should be referred to the
Enlarged Board of Appeal:
"Does the term 'technical' embrace the computerized activities of the
actuarial profession working in an industrial context?"
At the end of the oral proceedings the Board declared that it had decided
that the debate was closed and that the decision of the case was reserved.
IV.
The appellant explained that the data processing and computing means
according to the alleged invention formed the technical basis for
implementing a new pension system which was radically different from the
pension systems in existence before the filing date of the application.
The pension system according to the application was a full and reliable
funding scheme, reducing the financial and administrative burdens for
both sides, the employers and the employees, and achieving significant
advantages over the former pension systems.
The appellant argued that a distinction should be made between "doing
business" in terms of Article 52(2)(c) EPC and the present invention,
which consisted of a technical tool serving an actuary when doing its
job in the industry of business and fund management.
Furthermore, the claims were directed to the
- 7 - T 0931/95
processing of data which were related to physical entities, as was the
case in decision T 208/84 Computer-related invention/VICOM (OJ 1987,14)
and thus not directed to a pension system "as such", so that in the light
of Article 52(3) EPC the exclusion provisions did not apply.
Moreover, in view of decision T 1002/92 Queueing system/ PETTERSSON
(OJ 1995,605), the examining division should not have applied the
contribution approach when judging upon an invention with regard to
the exclusions under Article 52(2) and (3) EPC. In addition, relying on
the "technical character" of inventions was not justified, since such
a criterion was not set up by the European Patent Convention as a
requirement for patentability.
Apart from this the interpretation of the term "technical" as applied
in the present case was outdated and did not correspond to the ordinary
meaning of this term.
The practice to exclude business methods from patentability had been
abandoned in several non-European countries; with regard to the United
States of America, the appellant cited the decision State Street Bank &
Trust Co. v. Signature Financial Group, Inc., 1998, of the Court of Appeals
for the Federal Circuit of the United States of America and pointed out
that the USPTO had granted a patent on the appellant's pension system
in accordance with the present European patent application.
Furthermore, following decisions T 769/92, General
- 8 - T 0931/95
purpose management system/SOHEI (OJ 1995,525) and T 1002/92, Queueing
system/PETTERSSON the practice of the EPO had also changed, opening the
field of business methods to patent protection. The facts of the case in
decision T 1002/92, Queueing system / PETTERSSON resembled those of the
case at present before the Board so closely, that the decision had to
be followed when assessing patentability in the present case.
However, if the Board nevertheless would decide that technical character
was a requirement for non-exclusion from patentability, it was clear that
the present invention as claimed had a technical character. This applied
certainly to the apparatus claims, but also to the method claims which
comprised the use of data processing means, the latter constituting
technical means.
Reasons for the Decision
1. The appeal complies with the requirements of Articles 106 to 108 and
Rules 1(1) and 64 EPC and is thus admissible.
The requirement of technical character
2. According to the case law of the boards of appeal the use of the term
"invention" in Article 52(1) EPC in conjunction with the so-called
"exclusion provisions" of Article 52(2) and (3) EPC, which mention
subject-matter that "in particular shall not be regarded as inventions
within the meaning of paragraph 1", is understood as implying a
"requirement of technical
- 9 - T 0931/95
character" or "technicality" which is to be fulfilled by an invention
as claimed in order to be patentable. Thus an invention may be an
invention within the meaning of Article 52(1) if for example a technical
effect is achieved by the invention or if technical considerations are
required to carry out the invention (Case Law of the Boards of Appeal
of the European Patent Office, 3rd edition, 1998, chapter I.A.1;
Guidelines for examination C-IV.2.2).
For instance also in its most recent decisions concerning cases T 1173/97,
Computer program product/IBM (OJ 1999, 609) and T 935/97, Computer
program product II/IBM (not published in the OJ) the Board of Appeal
assumed that technical character of an invention was to be considered
as a generally accepted requirement of patentability.
Thus, in those cases the Board decided that a computer program product
(for instance the program itself) that had technical character was not
a computer program as such and was, therefore, not excluded from
patentability under Article 52(2) and (3) EPC. It consequently
represented a patentable invention (Reasons, par. 5).
Main request : Method claim
3. Following these decisions the question to be answered in the present
case is, whether the method according to claim 1 represents a method of
doing business as such. If the method is technical or, in other words,
has a technical character, it still may be a method for doing business,
but not a method for doing business as such.
- 10 - T 0931/95
Claim 1 of the main request is, apart from various computing means
mentioned in that claim, directed to a "method for controlling a pension
benefits program by administering at least one subscriber employer
account". All the features of this claim are steps of processing and
producing information having purely administrative, actuarial and/or
financial character. Processing and producing such information are
typical steps of business and economic methods.
Thus the invention as claimed does not go beyond a method of doing business
as such and, therefore, is excluded from patentability under Article
52(2)(c) in combination with Article 52(3) EPC; the claim does not
define an invention within the meaning of Article 52(1) EPC.
The appellant referred to the data processing and computing means defined
in the method claim, arguing that the use of such means conferred technical
character to the method claimed. However, the individual steps defining
the claimed method amount to no more than the general teaching to use data
processing means for processing or providing information of purely
administrative, actuarial and/or financial character, the purpose of each
single step and of the method as a whole being a purely economic one.
The feature of using technical means for a purely non-technical purpose
and/or for processing purely non-technical information does not necessarily
confer technical character to any such individual steps of use or to the
method as a whole: in fact, any activity in the non-technical branches of
human culture
- 11 - T 0931/95
involves physical entities and uses, to a greater or lesser extent,
technical means.
Arguments or facts which indicate that the individual steps of the method
or the method itself solves any particular technical problem or achieves
any technical effect, are not derivable from the patent application and
have not been submitted to the Board.
The Board notes that the mere occurrence of technical features in a claim
does thus not turn the subject-matter of the claim into an invention
within the meaning of Article 52(1). Such an approach would be too
formalistic and would not take due account of the term "invention".
The Board, therefore, concludes that:
Methods only involving economic concepts and practices of doing
business are not inventions within the meaning of Article 52(1) EPC.
A feature of a method which concerns the use of technical means for a
purely non-technical purpose and/or for processing purely non-technical
information does not necessarily confer a technical character to such
a method.
Case law cited by the appellant
4. In support of his request, the appellant cited decisions
T 208/84, T 769/92 and T 1002/92.
In T 208/84 Computer-related invention/VICOM, a "method for digitally
processing images" was
- 12 - T 0931/95
considered to be a technical process essentially for the reason that it
was carried out on a physical entity. The method did not merely add
information, but it produced a technical result by applying particular
digital image processing methods for example for enhancing and restoring
images. This technical character distinguishes the former case from the
case at present before the Board.
In T 769/92, General purpose management system/SOHEI, the method claim as
allowed opened with the words "method for operating a general-purpose
computer management system", the steps of the method being closely related
to functional features defining the computer system operated by this method.
The board in that case found that the invention had technical character
because it implied a need for technical considerations when carrying out
that invention. A technical invention could not loose its technical
character, because it was used for a non-technical purpose, like, for
instance, financial management. Therefore, the purpose of such a method
and of its individual steps remained a technical one, namely operating a
technical system, which ensured the technical character of the method itself.
In T 1002/92, Queueing system/PETTERSSON, a "system for determining the
queue sequence for serving customers at a plurality of service points"
was decided to be a three-dimensional apparatus and, therefore, clearly
technical in nature, which clearly distinguishes the subject-matter of
this case from that of the method claims of the present case.
- 13 - T 0931/95
First auxiliary request : Apparatus claim
5. The first auxiliary request seeks protection for an apparatus for
controlling a pension benefits system. In view of the pension system to
which the application relates the term "apparatus" may well be understood
to refer to an organizational structure. In addition, the term "means" as
used in the claim does not necessarily refer to hardware elements, or
hardware functions or combined hardware/software functions but its scope
may include organizational subunits and substructures for performing any
particular function having an economic or business character. Therefore,
the claim, when read in isolation, is amenable to be construed as claiming
a scheme for doing business only ie as such, which, according to Article
52(2)(c) and 52(3) EPC should not be regarded as an invention within the
meaning of Article 52(1) EPC.
The appellant's arguments, however, are based on an apparatus consisting
of a suitably programmed computer or system of computers. This
interpretation of the claim and in particular of the term "apparatus"
is supported by the manner the "computing means" are described with
reference to figure 3 in the application itself. This basis is accepted
by the Board in the framework of the present considerations.
In the Board's view 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.
- 14 - T 0931/95
This distinction with regard to patentability between a method for doing
business and an apparatus suited to perform such a method is justified in
the light of the wording of Article 52(2)(c) EPC, according to which
"schemes, rules and methods" are non-patentable categories in the field
of economy and business, but the category of "apparatus" in the sense of
"physical entity" or "product" is not mentioned in Article 52(2) EPC.
This means that, if a claim is directed to such an entity, the formal
category of such a claim does in fact imply physical features of the
claimed subject-matter which may qualify as technical features of the
invention concerned and thus be relevant for its patentability.
Therefore the Board concludes that:
An apparatus constituting a physical entity or concrete product
suitable for performing or supporting an economic activity, is an
invention within the meaning of Article 52(1) EPC.
The appellant's objections
6. The appellant has emphasized that technical character is not a
requirement for patentability under the EPC and that it is wrong to
apply the so-called contribution approach when deciding whether the
subject-matter concerned is an invention within the
meaning of Article 52(1).
The Board agrees with the appellant that in order to be patentable there
is not an explicit requirement of technical character of an invention
under Article 52
- 15 - T 0931/95
EPC or under any other provisions in Part II of the EPC which is concerned
with substantive patent law. Article 52, in particular in its paragraph 1,
only makes it clear that for something to be patentable, it must be an
invention.
However, having regard to the case law of the Boards of Appeal and taking
into account the frequent use of the term "technical" in the EPC and the
Implementing Regulations, which are an integral part of the EPC, and having
due regard to the context in which the term "technical" is used there,
the Board is of the opinion, contrary to the appellant's, that the
requirement of technical character is inherent to the notion "invention"
as it occurs in Article 52(1).
Thus the Board concludes that:
Having technical character is an implicit requirement of the EPC
to be met by an invention in order to be an invention within the
meaning of Article 52(1)EPC, following decisions T 1173/97 and T 935/97.
Consequently the Board fully agrees to the following passages in the
Guidelines for examination in the EPO: C-IV, 1.1 which it reads as
stating that Article 52(1) EPC comprises four basic requirements for
patentability, namely first of all that there must be an invention,
and furthermore that if there is an invention, that invention must
satisfy the requirements of susceptibility of industrial application,
novelty and inventive step,
- 16 - T 0931/95
the last sentence of C-IV, 2.2 stating that the basic test of whether
there is an invention within the meaning of Article 52(1), is separate
and distinct from the questions whether the subject-matter is susceptible
of industrial application, is new and involves an inventive step and
C-IV, 1.2, stating that "in addition to these four basic requirements"
the EPC and the Implementing Regulations contain implicitly the further
requirement that "the invention must be of technical character".
It may very well be that, as put forward by the appellant, the meaning of
the term "technical" or "technical character" is not particularly clear.
However, this also applies to the term "invention". In the Board's view
the fact that the exact meaning of a term may be disputed does in itself
not necessarily constitute a good reason for not using that term as a
criterion, certainly not in the absence of a better term,: case law may
clarify the issue.
The Board agrees with the appellant that the contribution approach is not
appropriate for deciding whether something is an invention within the
meaning of Article 52(1) EPC as the Board already noted in the earlier
decisions just mentioned.
According to the Board:
There is no basis in the EPC for distinguishing between "new features"
of an invention and features of that invention which are known from
the prior art when examining whether the invention concerned may be
considered to be an invention within the meaning of Article 52(1) EPC.
Thus there is no basis in the EPC for applying this so-called
contribution approach for this purpose.
- 17 - T 0931/95
The Board sees some contradiction in the Guidelines between, on the one
hand, the last sentence in C-IV, 2.2, just cited, where it says that the
basic test of whether there is an invention within the meaning of
Article 52(1), is separate and distinct from the questions whether the
subject-matter is susceptible of industrial application, is new and
involves an inventive step, and, on the other hand, the earlier part of
the same paragraph, where the application of the contribution approach
is explained as follows:
"the examiner should disregard the form or kind of claim and concentrate
on its content in order to identify the real contribution which the
subject-matter claimed, considered as a whole, adds to the known art. If
this contribution is not of a technical character, there is no invention
within the meaning of Article 52(1)". This confuses the requirement of
"invention" with the requirements of "novelty" and "inventive step".
Having regard to the desirable harmonisation of patent law it seems
appropriate to mention here the decision of the German Federal Court of
Justice (BGH) in case XZB 15/98, "Sprachanalyseeinrichtung", dated 11.05.00,
which, although it points out that "technical character " as a distinctive
criterion between patentable and non-patentable subject-matter is a rather
vague notion, applies it itself. It points out furthermore that
distinguishing between new and known features of a claim is not
appropriate for determining
- 18 - T 0931/95
whether an invention is excluded from patentability or not.
Inventive step
7. The Board, in the exercise of its discretional power pursuant to
Article 111(1) EPC, considers it appropriate to decide itself on the
issue of inventive step, without remitting the case to the examining
division for further prosecution.
The facts and arguments necessary for deciding on inventive step have
been produced in the proceedings before the first instance in the context
of the "contribution" approach as applied by the examining division in
order to decide that the invention as claimed did not constitute an
invention within the meaning of Article 52(1). This approach is so very
closely related to examination with regard to the requirement of inventive
step that the examining division decided in fact implicitly that there was
lack of inventive step under Article 56 EPC.
A remittal to the first instance for formal reasons only seems, therefore,
unacceptable in view of the overall time of procedure already passed in
the first instance and before the Board.
The Board considers it not necessary to reopen the debate in order further
to discuss inventive step since the facts and arguments necessary for
deciding on inventive step have also been discussed before the Board in
the same context as before the examining division and to the full extent.
- 19 - T 0931/95
Apart from this, the appellant's requests are directed to grant of the
patent which implies a full consideration of the requirements of the EPC
by the Board.
8. Although the subject-matter of claim 1 of the first auxiliary request
may be considered to represent an invention within the meaning of Article
52(1) EPC, it does not involve an inventive step in the sense of
Article 56 EPC.
In the decision under appeal the closest prior art is identified as the
"existing private pension plans" described in the application. The decision
furthermore explains that it would not be possible to understand from the
application any technical problem or contribution provided by the claimed
subject-matter to the prior art.
Indeed, the improvement envisaged by the invention according to the
application is an essentially economic one ie lies in the field of economy,
which, therefore, cannot contribute to inventive step. The regime of
patentable subject-matter is only entered with programming of a computer
system for carrying out the invention. The assessment of inventive step has
thus to be carried out from the point of view of a software developer or
application programmer, as the appropriate person skilled in the art,
having the knowledge of the concept and structure of the improved pension
benefits system and of the underlying schemes of information processing
as set out for example in the present method claims.
- 20 - T 0931/95
Regarding that the technical features of the apparatus claimed are
functionally defined by precisely those steps of information processing
which form part of the knowledge of the skilled person and that the
application of computer systems in the economic sector has already been
a general phenomenon at the priority date (filing date) of the application,
it must be concluded that the claimed subject-matter does not involve an
inventive step (Article 56 EPC).
9. Considering that in its second auxiliary request the appellant adds
only further functional features defined by steps of processing economic
data the same conclusion regarding Article 56 EPC as for the first
auxiliary request holds for this second auxiliary request.
10. The further auxiliary request of the appellant to refer the question
to the Enlarged Board of Appeal whether the term "technical" embraces the
computerized activities of the actuarial profession working in an
industrial context is rejected since this question has in the foregoing
already been answered by the Board itself, in the sense that it depends
on the specific circumstances of the case under consideration whether
the reply will be confirmative or not.
- 21 - T 0931/95
Order
For these reasons it is decided that:
The appeal is dismissed.
The Registrar: The Chairman:
M. Kiehl P. K. J. van den Berg