Patent Court Decision, 2019Heo6655, decided May 15, 2020 (Floodlight Lens Case )

The term “article” referred to in Article 2(i) of the old Design Protection Act
pertains to a tangible property with independence. An article must be
independently tradable in its normal state for it to be eligible for design
registration. If that article is a part of a product, then it implies its
compatibility. However, it does not necessarily mean that the part is traded
and compatible. It is eligible for design registration as long as it is the subject
of such an independent transaction and has the possibility of compatibility.
Even though the Subject Article, “floodlight lens,” is not an end product but
a part of a floodlight, the Subject Article should be considered compatible
and independently tradable by the traders who buy the Subject Article to
manufacture their floodlights, although it is rarely an independent trade item
for general consumers regarding to the manufacturing method of a floodlight,
selling ways, compatibility, etc.