Subitizing is the direct perceptual understanding of the numerosity of a group. Literally, it means instantly seeing how many.
The latest research appears to confirm that babies can subitize. Many studies suggest that babies can distinguish quantities up to three (Starkey & Cooper, 1980; Starkey,Spilke&Gelman1990;Strauss & Curtis 1981) This is shown by habituation studies. So long as the numbers are within their subitization range they do not seem to be dependent on the pattern in which the objects are arranged. If a baby is habituated to three items arranged in a triangular pattern (s)he will still treat them as the same old three if they are represented in a straight line. This contrasts with their reaction to numbers over 3. Tan and Bryant(2000) found that these can be recognized if, and only if, the pattern remained the same.
The Shichida Dot Cards show quantity randomly along with regular representations. I have not seen the complete set of Shichida cards(there appears to be a lot of secrecy about the Shichida methods?) but the images that i have seen indicate that fixed patterns and repeated grouping within the subitizing range might be used.