I would assume due to the different reverse is why the credit for the design went to Barber. Also the issue of the 20 cent piece was 38 years after the seated design was implemented, Gobercht had probably pass on by then.
Christian Gobrecht died 31 years prior to the use of the 20 cent piece but the obverse design is also not the same as other Seated Liberty coinage, most notably the shield and LIBERTY.
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