E-Mail via SMS, German Federal Supreme Court, 22 November 2011, Case No. X ZR 58/10
In the above judgment, the German Federal Supreme Court ruled on obviousness of improvements of data structures provided in an international standard, finding that a skilled person concerned with selectively improving a data structure provided in an international standard normally feels compelled to make recourse to mechanisms already envisaged by the standard for solving the technical problem. If an assessable number of possible problem-solving approaches arise from the standard, each of which has specific benefits and drawbacks, as a rule good cause is given to take each of these approaches into consideration.
Issues of "technical character" and/or "statutory exclusion" were neither raised by the parties nor by the Federal Supreme Court.