d) Requested amendments could already have been filed in opposition proceedings 

In T 2154/19 the board considered that the amendments requested at the oral proceedings before it could already have been filed at the opposition stage after the opposition division had found the main request not allowable at the oral proceedings. According to the board, that several different claim sets would have to have been filed at that point to overcome all the different novelty attacks addressed in the opposition proceedings was by no means an exceptional circumstance within the meaning of Art. 13(2) RPBA 2020.