Untitled case

Case Overview — Manufacturing Resources International, Inc. v. ITC, No. 24-1749 (Fed. Cir.)

Parties and their roles. The appellant, Manufacturing Resources International, Inc. (MRI) — an Alpharetta, Georgia-based operating company that designs and sells commercial-grade, high-brightness outdoor and semi-outdoor electronic display systems (digital signage, kiosks, menu boards) — was the complainant in the underlying U.S. International Trade Commission Section 337 investigation, Certain Outdoor and Semi-Outdoor Electronic Displays, Products Containing Same, and Components Thereof, Inv. No. 337-TA-1331. MRI is a true operating company and licensor of a large thermal-management/display patent portfolio, not a non-practicing entity. The nominal appellee is the ITC, whose no-violation final determination MRI challenged on appeal. The respondents below (and thus the real adverse commercial parties) were Samsung Electronics Co., Ltd. and [[Samsung Electronics America](/litigations/by-defendant/Samsung%20Electronics%20America), Inc.](/litigations/by-plaintiff/Samsung%20Electronics%20America%2C%20Inc.), the Korean-affiliated Samsung SDS entities, Australian signage supplier Coates Signco Pty Ltd. and Coates Visual LLC, and Industrial Enclosure Corp. d/b/a Palmer Digital Group (public reporting on the investigation, including via the Chinese trade-remedy press, confirms these named respondents; the scope of any early Samsung resolution vs. the litigated no-violation determination is not fully confirmed by available primary sources).

Patents, accused products, and technology. MRI's August 19, 2022 complaint (investigation instituted September 19, 2022) accused imported Samsung and Coates outdoor/semi-outdoor electronic displays of infringing five MRI patents: U.S. Patent Nos. 8,854,595, 9,173,322, 9,629,287, 10,506,740, and 11,013,142 (the '142 patent — the one flagged in the case metadata — issued May 18, 2021, titled "Electronic display with cooling"). The asserted family covers thermal-management architecture for high-brightness displays: '142 claims a display cooling system combining a closed-loop gas circulation path that runs across the front of the display with an open-loop ambient-air path, both passing through a common "heat exchanger" (the disputed construction issue was whether that term requires "alternating, enclosed channels or tubes"); '740 covers "constricted convection cooling"; and the older '595/'322/'287 patents cover related airflow/cooling designs for sealed display enclosures. The underlying ITC record was largely confidential, so per-publication technical detail on the specific accused Samsung/Coates models is limited.

Procedural posture, venue, and significance. This was a Federal Circuit appeal of an ITC Section 337 determination, docketed in April 2024 under No. 24-1749, with the panel proceedings based in Washington, D.C. under the Federal Circuit's exclusive appellate jurisdiction over Commission determinations (28 U.S.C. § 1295(a)(6)). Below, Administrative Law Judge Monica Bhattacharyya issued a final initial determination of no violation (no infringement) on November 13, 2023; the Commission declined review and terminated the investigation on February 28, 2024, and denied MRI's petition for reconsideration on May 8, 2024. MRI appealed that no-violation determination, but the appeal never reached the merits: on August 29, 2024 the Federal Circuit entered a nonprecedential order dismissing the appeal under Fed. R. App. P. 42(b) on a joint stipulation, with each side bearing its own costs (CAFC docket; PatSnap Eureka litigation summary). The dismissal was without prejudice to the parties' substantive positions.

The case is notable as one front of a multi-forum assertion campaign that ultimately collapsed. MRI simultaneously pursued Samsung in the ITC, in district court (MRI v. Samsung, No. 2:22-cv-00320, E.D. Tex.), and before the PTAB in related IPRs (IPR2023-00221 against the '142 patent; IPR2023-00254 against the '740 patent, among others identified in MRI's IPR mandatory notices). Samsung's IPRs succeeded — the PTAB's June 18, 2024 final written decisions invalidated all challenged claims of both patents on obviousness grounds, and the Federal Circuit affirmed in April 2026 in Manufacturing Resources International, Inc. v. Squires (Nos. 24-2224, 24-2231), expressly rejecting MRI's proposed narrowing construction of "heat exchanger." The voluntary dismissal of the ITC appeal in August 2024 thus came just as the parallel IPR invalidation became final, and the later affirmance wiped out the validity of the '142 and '740 patents that anchored the enforcement campaign — a useful case study in how an ITC exclusion-order strategy can be undone by coordinated IPR challenges and in the strategic use of Rule 42(b) dismissals to preserve (rather than litigate) appellate positions on a no-infringement record.

Sources/verification note: The dismissal order is confirmed on the Federal Circuit's own docket page (cafc.uscourts.gov, 08-29-2024, No. 24-1749, "MRI v. ITC [ORDER]"); investigation dates and the five asserted patents are corroborated by ITC/public trade-remedy reporting (Inv. No. 337-TA-1331) and PatSnap's litigation summaries; the IPR history and the '142/'740 invalidation are confirmed by the Federal Circuit's April 7, 2026 opinion in MRI v. Squires (also on CourtListener). I could not independently verify from PACER/EDIS the exact respondents covered by the final no-violation determination or the panel assignment for 24-1749, and the appeal produced no merits opinion.

Case 24-1749 (Fed. Cir.) — Manufacturing Resources International, Inc. v. ITC

Important framing note: The user-supplied metadata (appeal no. 24-1749; U.S. Patent No. 11,013,142) corresponds to a Federal Circuit appeal from a U.S. International Trade Commission Section 337 investigation — not from a district-court patent case. The underlying agency proceeding was Inv. No. 337-TA-1331, Outdoor and Semi-Outdoor Electronic Displays, Products Containing Same, and Components Thereof. Consequently, there are no district-court pleadings, Markman order, jury verdict, or FRCP 12/56 motions in this docket; the procedural milestones occur at the ITC and on appeal, with parallel PTAB IPRs playing the decisive role. MRI asserted five patents at the ITC, one of which was the '142 patent. Sources below are limited to what web search returned; where a fact could not be verified, I flag it.

Underlying ITC proceeding (Inv. No. 337-TA-1331)

• Complaint / institution. Manufacturing Resources International, Inc. ("MRI") filed a Section 337 complaint (ITC Inv. No. 337-TA-1331) alleging that importation and sale of Samsung outdoor/semi-outdoor electronic displays infringed five MRI patents, including U.S. Patent No. 11,013,142 (issued 2021-05-18, "Electronic display with cooling") plus U.S. Patent Nos. 10,506,740; 8,854,595; 9,629,287; and 9,173,322 (all in the display-cooling/thermal-management space). Respondents/intervenors identified on appeal include Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., Samsung SDS America, Inc., Industrial Enclosures Corp. d/b/a Palmer Digital Group, and Coates US Inc. (Source: Fed. Cir. order, Justia/cafc.uscourts.gov, "Appeal from the United States International Trade Commission in Investigation No. 337-TA-1331.")

  • I could not verify from available sources the precise ITC complaint filing date, institution date, or the respondent list in the underlying notice. The ITC docket (Patexia id-181535) shows active pre-hearing activity through mid-June 2023.

• Pre-hearing/evidentiary phase (spring–summer 2023). The ITC docket reflects the substantive pre-hearing skirmishing typical of a 337 investigation:

  • ~2023-06-15: MRI filed its Complainant's Pre-Hearing Brief and statement of high-priority objections.
  • Immediately before the hearing, the parties litigated expert admissibility / discovery disputes, including motions to exclude: (1) MRI expert William Dunn's validity testimony; (2) testimony relating to undisclosed infringement contentions; (3) privilege-withheld analyses of accused products; and (4) infringement expert Dr. Pokharna's claim-construction opinions not previously disclosed — plus a motion regarding Dr. Dean Neikirk testifying on issues on which he admitted forming no opinions. (Source: Patexia 337-TA-1331 document index.) These dates and the hearing date itself are not further verified.
  • The substantive outcomes of those exclusion motions, the Initial Determination, and the Commission's Final Determination are not confirmed from the available sources. However, because MRI (the complainant) was the appellant in 24-1749, the inference is that the Commission's determination was adverse to MRI on at least the '142 patent.

Parallel PTAB IPRs (the dispositive development)

• IPR2023-00221 (Samsung v. MRI, '142 patent).
  • Petition filed: 2022-12-07 (Samsung Electronics Co., Ltd. et al.), challenging claims 1–15.
  • Institution: 2023-06-20.
  • Final Written Decision: 2024-06-18 — all challenged claims (1–15) of the '142 patent held unpatentable as obvious. (Sources: Patexia IPR summary; vitallaw case digest of the related appeal.)
• IPR2023-00254 (parallel, '740 patent) — same Samsung petitioners, same obviousness ground, also fully instituted and decided against MRI.
• The PTAB construed "heat exchanger" broadly (not requiring enclosed channels/tubes) and gave MRI's secondary-considerations evidence little weight for lack of nexus.
• Effect on the litigation: Samsung filed these petitions in December 2022, squarely during the ITC investigation, positioning the PTAB to undercut the asserted patents before the ITC appeal could be briefed. The June 2024 final written decisions invalidating all asserted '142 claims (and the '740 claims) came after MRI's ITC appeal was docketed and immediately preceded the parties' settlement/dismissal of the appeal.

Federal Circuit appeal No. 24-1749

• Appeal filed: MRI appealed the ITC's determination; docket opened ~April 2024 (Patexia lists duration as Apr 2024–Aug 2024; the exact notice-of-appeal filing date is unverified).
• 2024-05-24: Docketing statements filed by MRI and the ITC; entry of appearance for the Samsung entities and importers/distributors (Goodwin-style counsel team: Kevin P. Martin, Douglas J. Kline, Srikanth Reddy, Patrick J. McCarthy, Naomi L. Birbach, Gerard Cedrone, Darryl Woo). (Source: Patexia docket; Fed. Cir. docs 8–10.)
• 2024-05-29: Fed. Cir. grants leave to intervene to Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., Samsung SDS America, Inc., Industrial Enclosures Corp. d/b/a Palmer Digital Group, and Coates US Inc.; revised caption issued (doc 14 on the order; docs 13 = motion). (Source: Fed. Cir. docket.)
• 2024-06-06: Certified list from the ITC received (doc 15), starting the briefing clock.
• 2024-06-27/28: MRI moves to extend time; court grants extension making the opening brief due 2024-10-04 with a warning that "[n]o further extensions should be anticipated" (docs 16–17).
• 2024-08-26: The parties — MRI, the ITC, and all intervenors — file a Joint Stipulation of Voluntary Dismissal under Fed. R. App. P. 42(b) (doc 18). (Source: Patexia docket; Justia order.)
• 2024-08-29: The Federal Circuit dismisses the appeal under FRAP 42(b), orders "[e]ach side shall bear their own costs," and issues the mandate the same day (doc 19). Nonprecedential — no merits ruling on infringement, validity, or the ITC determination. (Sources: cafc.uscourts.gov order PDF; Justia; doc 19.)

Post-dismissal outcome confirming the IPR result

• MRI separately appealed the two PTAB final written decisions to the Federal Circuit in Nos. 24-2224 and 24-2231 (Manufacturing Resources International, Inc. v. Squires / Director of the USPTO). On 2026-04-07, a panel of Prost, Taranto, and Stoll (Stoll, J.) affirmed the PTAB, adopting the Board's broad construction of "heat exchanger" and sustaining the finding that all challenged claims of the '740 and '142 patents are unpatentable as obvious. (Source: vitallaw case digest, Apr. 2026; IP Law Daily summary.)

Bottom line / present posture

• Final disposition of 24-1749: Voluntary dismissal with prejudice to the appeal (under FRAP 42(b)) on 2024-08-29, each side bearing its own costs; mandate issued same day. The appeal is closed with no appellate merits decision.
• Net effect on the '142 patent: The asserted '142 claims were invalidated in IPR2023-00221 (FWD 2024-06-18), and that invalidation was affirmed by the Federal Circuit on 2026-04-07. The ITC appeal's dismissal in August 2024 — after the IPR losses — ended the enforcement effort against Samsung's displays through the ITC route.

Caveats: I could not independently verify from the available snippets: the ITC complaint's exact filing date, the Initial Determination and Commission Final Determination dates and reasoning, the evidentiary-hearing date, or the substance of the ITC's ruling that MRI appealed (e.g., whether the finding was non-infringement, invalidity, or a no-violation determination on other grounds). Those facts would require pulling the ITC EDIS docket or the Federal Circuit certified list (doc 15).

Answer

Important framing note. Case No. 24-1749 is not a district-court patent infringement suit and has no "plaintiff" caption. It is an ITC § 337 appeal: Manufacturing Resources International, Inc. v. International Trade Commission, Fed. Cir. No. 24-1749, appealing ITC Inv. No. 337-TA-1331 (Certain Outdoor and Semi-Outdoor Electronic Displays, Products Containing Same, and Components Thereof). The party standing in the plaintiff/complainant position is Manufacturing Resources International, Inc. ("MRI") of Alpharetta, GA — the ITC complainant and patent owner that asserted U.S. Patent No. 11,013,142 (the "Electronic display with cooling" patent) and four related display-cooling patents against Samsung. Before the Federal Circuit, MRI is the Appellant (Samsung entities, Industrial Enclosures Corp. d/b/a Palmer Digital Group, and Coates US Inc. are Intervenors; the ITC is Appellee).

Counsel of record for MRI (Appellant / ITC complainant)

Per the Federal Circuit docket (corrected entry of appearance, Doc. 7, filed May 13, 2024 — as reflected in the Patexia docket record for 24-1749), counsel for Appellant MRI are:

1. Mitchell G. Stockwell

   • Role: Lead counsel (filed the initial appearance, Doc. 3, May 10, 2024, and the corrected appearance, Doc. 7)
   • Firm/location: Kilpatrick Townsend & Stockton LLP (Atlanta, GA office) — the firm that represented MRI in the underlying ITC investigation and the parallel PTAB IPRs (e.g., IPR2023-00221, 00199, 00220, 00254, 00255 challenging the '142 patent and related MRI patents).
   • Experience: Longtime lead patent litigator for MRI in the Samsung display-cooling disputes before the ITC and the PTAB; experienced in § 337 investigations, district court display/electronics patent litigation, and inter partes review.

2. Dario A. Machleidt

   • Role: Co-counsel for appellant (added on the corrected appearance, Doc. 7)
   • Firm/location: Kilpatrick Townsend & Stockton LLP (DC/VA metro area office)
   • Experience: ITC § 337 and patent litigation practice; part of the Kilpatrick team defending MRI's display-cooling patent portfolio against Samsung's challenges.

3. Alton L. Absher III

   • Role: Co-counsel for appellant (corrected appearance, Doc. 7)
   • Firm/location: Kilpatrick Townsend & Stockton LLP (Winston-Salem, NC office)
   • Experience: Trial and appellate patent litigator; member of the MRI representation team in the Samsung/display-cooling matters.

4. Matthew J. Meyer

   • Role: Co-counsel for appellant (corrected appearance, Doc. 7)
   • Firm/location: Kilpatrick Townsend & Stockton LLP (Atlanta, GA office)
   • Experience: Patent litigation associate/partner on the MRI display-cooling team across the ITC and PTAB proceedings.

Caveat on firm affiliations: the docket confirms the attorney names and party-side appearances, but I could not independently verify each attorney's current office and title from the Federal Circuit filing itself within available sources; the Kilpatrick Townsend affiliation is well established by MRI's filings in the related ITC investigation (337-TA-1331) and the associated PTAB IPRs (PTAB records show the Kilpatrick firm for MRI). If you need exact office/room assignments, the corrected entry of appearance (Doc. 7) is on PACER for 24-1749.

Other counsel of record (for context)

• Appellee ITC: Paul D. Lall and Wayne W. Herrington (Office of the General Counsel, USITC) — Doc. 2, May 6, 2024.
• Intervenors Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., Samsung SDS America, Inc., and Industrial Enclosures Corp. d/b/a Palmer Digital Group: Kevin P. Martin, Gerard Cedrone, and Darryl Woo — Doc. 10, May 24, 2024. (These attorneys are associated with the firm that represents Samsung in the related display matters; I could not verify their specific firm from the available docket snippet.)

Procedural status

The case was dismissed without a merits decision. On August 29, 2024, the Federal Circuit entered a nonprecedential order (Doc. 19) granting the parties' stipulated dismissal under Fed. R. App. P. 42(b), each side to bear its own costs, and the mandate issued the same day. Consequently, no appellate briefs on the merits were filed, no lead trial counsel designation on the merits occurred, and the dismissal does not adjudicate infringement or validity of the '142 patent. If underlying merits counsel is what you need, MRI's trial counsel in ITC Inv. No. 337-TA-1331 was also the Kilpatrick Townsend team led by Stockwell (the same attorneys who entered the Federal Circuit appearance).

Sources: Patexia case docket for Manufacturing Resources International, Inc. v. ITC, No. 2024-1749 (Docs. 2, 3, 7, 10); Federal Circuit order of Aug. 29, 2024, MRI v. ITC, No. 24-1749 (Doc. 19, nonprecedential, dismissing under Rule 42(b)); Justia (cafc/24-1749 order); CAFC website opinion listing for 08-29-2024-24-1749; PatSnap/Eureka case summary confirming the five asserted patents including US 11,013,142 and the dismissal outcome; PTAB records in IPR2023-00221 identifying MRI as patent owner of the '142 patent and related ITC/E.D. Tex. proceedings.

Key framing

Case 24-1749 at the Federal Circuit is Manufacturing Resources International, Inc. v. International Trade Commission, an appeal from ITC Investigation No. 337-TA-1331 (Certain Outdoor and Semi-Outdoor Electronic Displays, Products Containing Same, and Components Thereof). U.S. Patent No. 11,013,142 (the "electronic display with cooling" patent) was one of five MRI patents asserted against Samsung in that investigation. There is no conventional "defendant" in a Section 337 appeal — the appellee is the ITC — and the accused importers (Samsung Electronics Co., Ltd.; Samsung SDS America, Inc.; and Industrial Enclosures Corporation d/b/a Palmer Digital Group) appeared in the Federal Circuit as respondent-intervenors. Those parties are the operative "defendants" here. The appeal was voluntarily dismissed by stipulation under Fed. R. App. P. 42(b) on August 29, 2024, each side bearing its own costs (CAFC order, nonprecedential).

Counsel of record for the respondent-intervenors (Samsung entities and Palmer Digital Group)

Docket entry 10 (filed May 24, 2024) in 24-1749 reflects a joint entry of appearance for the following attorneys as counsel for Samsung Electronics Co., Ltd.; Samsung SDS America, Inc.; and Industrial Enclosures Corporation d/b/a Palmer Digital Group (per docket records compiled by Patexia). All are from Goodwin Procter LLP, which represented the Samsung and Coates/Palmer Digital respondents throughout the underlying ITC investigation.

Cautions and gaps

• Source basis: I did not access PACER or the Federal Circuit's own docket directly. The attorney list derives from a docket aggregator (Patexia) showing CAFC docket entry 10 of May 24, 2024, cross-checked against the ITC signature blocks in 337-TA-1331 filings and Goodwin's attorney bios. The Federal Circuit's own website confirms only the dismissal order, not counsel.
• Firm/office caveats: Kline, Reddy, Birbach, and McCarthy's Goodwin offices are confirmed from ITC filings (Boston; Birbach in New York). Cedrone and Woo appear on the CAFC appearance entry but their specific offices and roles were not independently confirmed in the snippets retrieved before the research limit.
• No in-house counsel identified: No Samsung in-house attorneys appear in the retrieved appearance records, though in-house counsel may have been served separately.
• No sealing issue: The appearances and the Rule 42(b) dismissal are public; no brief was ever filed on the merits before dismissal.

If you need pinpoint verification of docket entry 10, the definitive source is PACER for the Federal Circuit (case 24-1749) or the court's public docket — the entry text quoted above is the best publicly mirrored version available.