Design Application 29/404,677 is directed to a tread for a shoe bottom. The application has two figures showing a plan view of the shoe bottom (page 2). The Examiner and board alleged that the design claims were not enabled and indefinite due to lack of other views to determine depth and contour (pages 3-6). A patent’s claims must inform those skill in the art about the scope with reliable certainty in order to provide notice of what would infringe (page 9). An ordinary observer may judge from a two-dimensional plan view, so the drawing enables and is clear (pages 12-13). The drawing provides the perspective from which the judgement should be made (page 13).
Hindsight: For narrower claims, drawings from different perspectives may be included. For broader design coverage, a 2D plan view may be used. The court pointed to some example objects needing 3D information (e.g., tea pot), so broadly claiming by a single 2D image may not work in some cases. In this case, the tread on a generally planar bottom of a shoe is a subject matter for which 2D is definite.