Summer Associate Tash Medde-Witage contributed to this article.
The first three articles in our Protecting Software with GUI Design Patent Series examined the growing importance of graphical user interfaces (GUIs) and recent developments in their protection under U.S. design patent law. But the evolution of GUI protection extends well beyond the United States. As digital interfaces become an increasingly important part of the product experience, design offices around the world are confronting how existing protection frameworks should accommodate new forms of digital interaction.
Through the Industrial Design Five Forum (ID5), the world’s five largest design offices regularly collaborate on issues involving digital designs, emerging technologies, and the harmonization of design examination practices. The ID5 comprises the United States Patent and Trademark Office (USPTO), China National Intellectual Property Administration (CNIPA), European Union Intellectual Property Office (EUIPO), Japan Patent Office (JPO), and Ministry of Intellectual Property of the Republic of Korea (MOIP).
Historically, applicants sought protection for static screen displays associated with conventional computing devices. As GUIs become increasingly sophisticated, however, applicants are increasingly seeking protection for visual experiences that extend beyond traditional screen-based interfaces, prompting design offices to evaluate how existing design protection frameworks should evolve.
Recent developments in the United States and India illustrate this evolution. As discussed in earlier installments of this series, the USPTO took one approach in March 2026, issuing supplemental examination guidance that gives applicants greater flexibility in satisfying the article-of-manufacture requirement for computer-generated interfaces and icons. The guidance removes the requirement that the associated article of manufacture be depicted in the drawings under specified circumstances and expressly addresses interfaces such as projections and holograms whose appearance may be separate from the computer or computer system that generates them.
India is likewise considering how its existing design framework applies to GUIs and icons. Draft guidelines issued under India’s Designs Act and Rules recognize both static and dynamic GUIs and clarify that a GUI’s visibility only when a device is powered on, non-permanent, or non-tactile does not, by itself, preclude registrability. At the same time, the draft guidelines require a GUI or icon to be applied to an article and provide that a standalone GUI or icon is not registrable. The draft also addresses the presentation of dynamic GUIs.
These developments reflect a broader effort to adapt design protection to increasingly sophisticated digital interfaces, while also demonstrating that important jurisdictional differences remain regarding the relationship between a GUI and an article, application and representation requirements, and treatment of dynamic interfaces.
Despite these jurisdictional differences, GUI protection has become a central component of international design practice. As products become increasingly software-driven and digital experiences continue evolving, GUI protection will likely remain at the forefront of design law developments around the world.
This article is the fourth installment in the Protecting Software with GUI Design Patents series.