[lit@3.1.0] the inferred type of 'render' cannot be named without a reference

### Which package(s) are affected?

Lit Core (lit / lit-html / lit-element / reactive-element)

### Description

While migrating to the latest version of lit (3.1.0), I stumbled upon the following ts error in [one](https://github.com/justeattakeaway/pie/blob/main/packages/components/pie-modal/src/index.ts) of our components.

The issue only happens if you're importing `html` from `lit/static-html.js` and using lit@3.1.0

I think this might be related to the [lit-html@3.1.0](https://github.com/lit/lit/commit/949a54677748a1f83ec4d166bd40e244de3afda7) version bump as one of our dependencies `@open-wc/testing@3.2.2` was still pointing to an older version, resulting in the error.

upgrading `@open-wc/testing` to `latest | 4.0.0` seems to fix the issue for us but wanted to document the issue and bring it to the team's attention just in case other areas are affected ⭐

feel free to close the issue if all is good and no action is needed 🤝

### Reproduction

install `@open-wc/testing@3.2.2` in a typescript project with `lit@3.1.0` and have this simple lit element

```
import { LitElement } from 'lit';
import { html } from 'lit/static-html.js';

class Greeting extends LitElement{
render () {
return html`

`;
}
}
```

### Workaround

make sure `lit-html` is pointing to the latest version either by updating the package that relies on it such as `@open-wc/testing` or adding a resolution entry to pakcage.json

### Is this a regression?

Yes. This used to work, but now it doesn't.

### Affected versions

3.1.0

### Browser/OS/Node environment

typescript@5.1.3

Start by reproducing the TypeScript error from packages/components/pie-modal/src/index.ts with lit@3.1.0 and @open-wc/testing@3.2.2. Check the dependency versions and package.json resolution workaround described in the issue, then determine whether Lit needs a change; done means confirming a Lit fix or documenting that upgrading the dependency resolves it.

Written by the indexing model from the issue text.