In LKQ v. GM, a May 21, 2024 en banc decision on an appeal of an IPR final written decision determining that the challenged claim of GM’s U.S. Design Patent No. D797,625 (directed to the design for a vehicle front fender) was not obvious, the Federal Circuit vacated and remanded the PTAB’s decision, overruling the Rosen-Durling test for obviousness of design patents and articulating general guidance for a new obviousness test it determined was more consistent with Supreme Court authority, in particular the “flexible standards” applied in Smith v. Whitman Saddle Co., 148 U.S. 674 (1893), Graham v. John Deere, 383 U.S. 1 (1966), and KSR v. Teleflex, 550 U.S. 398 (2007).