From Case Law T 0858/02 - 3.5.3 of the Boards of Appeal of the European Patent Office:
"Catchword:
1. When considering the nature or category of a claimed invention attention must be paid to the substance of what is claimed, rather than only taking into account how the claimed subject-matter is designated, which can be deceptive.
2. An electronic message is not automatically excluded from patentability under Article 52(2)(d) EPC as a presentation of information. This will depend on whether the message is defined by its structure or its content."
So yet more drivel from the BoA as to what is considered patentable under Art. 52. The structure of an e-mail, c'mon !!! Errm, now let me see, where did I leave those RFCs ;-)