In Curver Luxembourg, SARL v. Home Expressions, Inc., the Federal Circuit addressed for the first time the role that the article of manufacture specified in a design patent description plays in defining the scope of design patent protection. The plaintiff in the case argued that its design patent protection should extend to any article of manufacture using the patented design notwithstanding that the granted patent application specified that the design was for a chair. Representing a coalition of open source hardware designers, the Samuelson Clinic explained how unmooring a design patent from the article manufacture vitiates the notice function of the design patent and grants the patentee unwarranted protection of abstract designs. An overbroad and uncertain scope of design patent protections creates undue risk for open source hardware designers who freely share and modify hardware designs. The Federal Circuit agreed with our client’s position and held that in appropriate cases, the article manufacture limits the scope of a design patent.