화상디자인 제도의 비교법적 고찰: UX 디자인과의 정합성을 중심으로

This study was undertaken against the backdrop of evolving valuations and legal standards for graphic image design rights over the past decade and emerging questions about their alignment with UX design. The purpose of the study is to conduct a comparative legal analysis of screen design protection in major jurisdictions from a UX perspective and to derive implications for future system reform and cross-border filing strategies. Accordingly, the analysis examines design protection frameworks in Korea, the US, the UK, the EU, Canada, Australia, and Singapore, focusing on UX-salient dimensions such as temporality, state transitions, and contextual adaptability as represented through UI state models, and compares each jurisdiction’s eligibility criteria and examination practices. The key findings are as follows. First, a gap between regimes that require linking graphic image designs to a physical product and those that recognize non-physical UIs as protectable leads to divergent eligibility and scope determinations in AR/VR/HUD contexts. Second, reliance on static image snapshots in current applications makes it difficult to convey a UI’s temporal continuity and interactive context, raising concerns that examination may emphasize formal compliance (e.g. view count limits, labeling rules) over substantive design logic. Third, as compliance with accessibility and other functional standards renders many UI elements commonplace, the overall scope of protection tends to narrow. Thus, without careful calibration between clarity of claimed scope and breadth of coverage, consistency in originality (individual character) determinations can be undermined. Based on these findings, this study suggests directions for UX-oriented improvements to graphic image design protection systems and proposes a unified representation strategy with minimal jurisdiction-specific adjustments to enhance interpretive clarity, examination reliability, and the effectiveness of international filings.