The Federal Circuit’s latest design-patent decision carries immediate, practical lessons for chemical-materials companies that launch novel chemistries in distinctive products, such as textiles, containers, and packaging. 

In Range of Motion Products, LLC v. Armaid Company Inc., No. 2023-2427 (Fed. Cir. Feb. 2, 2026), the court affirmed non-infringement after filtering functional features before comparing only remaining ornamentation, an approach with direct implications for dual filing. 

This piece distills the holding, explains why filing utility and design together remains smart, and offers a concise, materials-focused playbook in light of the case.

Design scope narrows when function dominates

The Federal Circuit affirmed non-infringement after filtering out functional features and concluding the accused design was plainly dissimilar under the ordinary-observer test. The panel endorsed a detailed functionality screen, drawing on utility patents and marketing, before comparing only remaining ornamental aspects. A dissent warned this framing invites courts to resolve close cases on summary judgment. 

Why does this matter in chemicals and materials?

Materials companies sell performance wrapped in various form, such as textiles, apparel, bottles, tissues/wipes, films, liners, dispensers, and housewares, where look and surface cues influence buyers. Dual filing remains sound, but if the record stresses function, design scope can shrink to leftover ornamentation, making early non-infringement more likely. 

What are the legal levers that will shape your outcomes?

• Functionality filtering can narrow scope; courts look to utility patents, marketing, and engineering evidence.
• Solid/dashed lines do not decide functionality; drawings are not conclusive.
• Ordinary-observer comparison occurs after filtering and in light of prior art; plainly dissimilar designs can end cases early. 

Why file both utility and design for chemical-materials products?

• Complementary coverage: utility protects performance; design protects distinctive look and surface cues-together they deter both functional and styling workarounds.
• Speed and signaling: design patents often issue fast; keep the record from over-functionalizing the design so early rights remain meaningful.
• Practical deterrence: dual rights raise design-around costs in packaging and applicators where look-and-feel matters. 

Practical drafting playbook for materials teams seeking both designs and utilities

1. Map function vs. ornament early; document feasible aesthetic alternatives for key features to support ornamentality.
2. Align narratives: avoid calling intended design features “necessary” in the utility spec; note alternatives.
3. Drawings: show signature look in solid lines; push standardized/functional interfaces into broken lines; include variants.
4. Prior art framing: curate a crowded field so small ornamental differences matter to the ordinary observer.
5. Marketing: avoid positioning visual features as performance-critical; emphasize brand and user experience.
6. Portfolio hygiene: use continuations/partials to protect themes across SKUs and sizes. 

Textile and fiber-based product examples

• Nonwoven disinfectant wipes and canisters: utility on chemistry/absorbency and dispensing mechanics; design on wipe pattern, canister shoulder transitions, lid silhouette, and rib patterns. Guard against marketing that ties wipe pattern or ribs to performance.
• Performance apparel and athleisure: utility on fiber blends, moisture-management knits, and seam constructions; design on panel geometry, vent perforation patterns, and ornamental weave/print placements that create a signature look. Avoid calling a particular panel shape “necessary” to wicking.
• Technical filtration media and cartridges: utility on pleat density and media chemistry; design on end-cap bezel contours, window cutouts, and handle geometries visible to purchasers. Keep functional interfaces in broken lines.
• Carpet tiles and floor mats: utility on backing chemistry and stain resistance; design on face patterning and tile layout motifs that drive purchasing decisions.

Bottom line for chemical materials companies

File utility and design together, but align your story, so design rights retain real ornamental scope: document alternatives, draw strategically, curate prior art, and tune marketing. Done well, design patents will complement your utility portfolio and deter both functional and styling workarounds.