Until recently, the disgorgement of profits remedy in US design patent law garnered little attention from scholars or practitioners. Congress created this remedy in the late nineteenth century to overrule two Supreme Court decisions that awarded nominal damages as the sole compensatory remedy for infringements of design patents. Under the new remedy, a design patentee could ask for a disgorgement of the "total profit" that an infringer made from sales of articles of manufacture to which the infringing design had been applied. Patented designs back then were generally co-extensive (or nearly so) with the appearance of products sold in the marketplace, and Congress was told when it adopted the total profit remedy that the design "sells the article." These conditions made it plausible to legislators that little or none of the profit on the sale of an infringing article was attributable to other elements of the article (e.g., quality of materials used or craftsmanship of its manufacture), and that the infringer captured profits it would have been unable to earn had it not infringed the design patent. However, in the modern era, it has become quite common for design patents to issue on small parts, features, or components of complex products and on designs that are more functional than ornamental. Changes in the nature of the design patent entitlement have precipitated a crisis about how to interpret the "total profit" remedy now codified as § 289 of US patent law.