In a decision which has just become available, a European Patent Office (EPO) Board of Appeal, in discussing the EPO case law on exclusions from patentability under Article 52(2) and (3) of the European Patent Convention (EPC), has severely criticised the approach to these provisions taken by the English Court of Appeal in the Aerotel/Macrossan decision: the EPO Board of Appeal stated that the Court of Appeal's approach was "irreconcilable" with the EPC. This difference in approach makes life difficult for applicants, who can expect to have applications treated differently depending on whether they file in Europe or the UK. It also creates uncertainty for the holder of a European patent for a computer-implemented invention who wants to assert it in the UK. Case: T 0154/04 3.5.01 Method of estimating product distribution/DUNS LICENSING ASSOCIATES, 15 November 2006.