f) Change of representative 

In T 1904/16 the board considered that the belated submissions (new evidence and new line of argument concerning public availability of D16) were not justified by the change of representative shortly before the oral proceedings. It recalled that a change of representative was a fact which belonged to the sphere of the party affected and, being extraneous to the proceedings, could not influence the decision whether a procedural action had been performed in time. On the contrary, a new representative was bound by the procedural actions performed by their predecessor and continued the proceedings from the point reached when they took over (see also T 1585/05). The board concluded that a change of representative as such was not a sufficient justification for late filings (see Case Law of the Boards of Appeal, 9th ed. 2019, V.A.4.8.2) and – under the circumstances in the case in hand, where the issue to be overcome had been raised at the outset – certainly not a cogent reason within the meaning of Art. 13(2) RPBA 2020.