December 2011 Alicante News reports a decision on designs not visible in normal use in violation of CDR Art 4(2). This was a Pole-on-Pole dispute (A.C.V. Manufacturing vs. AIC, ICD 8325, not yet on the website), concerning RCD 1618703-0001. It depicts a heat exchanger, which is the tubular part shown in situ to the left - the drawings of the registration show the product in isolation, so I imagine the picture here was supplied by the opponent.
OHIM's decision followed their earlier case law (Case ICD 5502 concerning RCD 831995-0002, discussed here) in requiring not merely the theoretical possibility that a part might be visible in some notional use, but proof that the normal use would be visible. Before they ceased to examine applications, that was also the practice of the UK IPO (See Designs Practice Notice DPN 1/03).