35 U.S.C. 289 provides a "additional remedy" for infringement of a US design patent: the total profits from the sale of the infringing "article of manufacture." Last December, the Supreme Court overturned decades of caselaw in which courts had uniformly concluded the "article of manufacture" was always the entire infringing product, as sold by the infringer. However, the Supreme Court did not articulate a legal standard for determining the proper article of manufacture and