Manufacturing Resources International, Inc. v. John A. Squires, Director of the United States Patent and Trademark Office

Case Overview & Background

Parties and underlying dispute. This matter—captioned Manufacturing Resources International, Inc. v. Squires, Nos. 24-2224, -2231 (Fed. Cir.)—is not a district-court infringement case; it is the Federal Circuit's appellate review of two PTAB inter partes review final written decisions, in which the USPTO Director (now John A. Squires) appears as the intervenor-defender after the real party in interest, Samsung, exited the appeal. The appellant, Manufacturing Resources International, Inc. ("MRI"), is an Alpharetta, Georgia-based operating company—not an NPE—that designs and sells thermal-management/cooling systems for outdoor and semi-outdoor electronic displays (digital signage) and describes itself as a worldwide leader in that market (IPR2023-00254, Paper 7, Patent Owner's Preliminary Response; RPX/Unified Patents classify it "operating company"). The patents-in-suit are U.S. Patent Nos. 10,506,740 ("Electronic display with cooling," issued Dec. 10, 2019) and 11,013,142 (a continuation issued May 18, 2021, sharing the same specification), both claiming systems that cool an electronic display using two interacting flow paths—a closed-loop gas circulation path that runs across the front of the display and to the rear, and an open-loop ambient-air flow path—that exchange heat through a common "heat exchanger." Samsung Electronics Co., Ltd. and [Samsung Electronics America, Inc.](/litigations/by-plaintiff/Samsung%20Electronics%20America%2C%20Inc.) were the IPR petitioners and the original appellees here; the accused products are Samsung's imported outdoor/semi-outdoor electronic displays, which MRI pursued in parallel before the ITC (Inv. No. 337-TA-1331, "Certain Outdoor and Semi-Outdoor Electronic Displays") and in E.D. Tex. (Manufacturing Resources Int'l, Inc. v. Samsung Electronics Co., Ltd., No. 2:22-cv-00320, filed Aug. 19, 2022, Judge Rodney Gilstrap, with referral to Magistrate Judge Roy S. Payne; the complaint asserted the '740, '142, and three related MRI display-cooling patents: '595, '322, and '287).

Procedural posture. Samsung filed IPR2023-00254 (challenging claims 1–3, 5–9, 11–13, 15–18, and 20 of the '740 patent) on Dec. 13, 2022, and IPR2023-00221 (challenging claims 1–15 of the '142 patent) on Dec. 7, 2022. The PTAB instituted both on June 20, 2023; the same panel (APJs Jameson Lee, author of the final decisions; Jo-Anne M. Kokoski; John A. Hudalla) held a consolidated oral hearing on March 20, 2024, and issued final written decisions on June 18, 2024, holding all challenged claims unpatentable as obvious over combinations including Karppanen and Yare (with Larson in the '142 IPR), construing "heat exchanger" broadly ("may, but does not have to, include enclosed channels or tubes") and discounting MRI's objective indicia of nonobviousness for lack of nexus. MRI appealed both decisions on Aug. 16, 2024 (Nos. 24-2224 and 24-2231); the appeals were consolidated on Aug. 30, 2024, with 24-2224 as lead. Samsung was terminated as appellee on Sept. 24, 2024, and the USPTO Director intervened—through successive Directors Vidal, Brent, and Stewart before Squires—to defend the Board, reflecting the modern post-Arthrex posture in which the PTO defends PTAB decisions the agency's own Board rendered. The Federal Circuit's appellate jurisdiction over IPR appeals is exclusive under 28 U.S.C. § 1295(a)(4)(A), which is the only "venue" question here (the merits panel was Prost, Taranto, and Stoll; Judge Stoll authored the decision). On April 7, 2026, the court issued a nonprecedential opinion affirming in full, adopting the Board's "heat exchanger" construction under Phillips, Thorner, and Intel Corp. v. Qualcomm Inc. (finding no lexicography or disavowal in the shared specification, which stated "many types of heat exchangers are known"), and rejecting MRI's secondary-considerations arguments as largely foreclosed by the court's related March 31, 2026 opinion in MRI v. Squires, No. 2024-2228 (affirming invalidation of the related '595/'322 patents).

Why the case is notable. This appeal is the tail end of a coordinated, multi-front enforcement campaign: MRI filed its E.D. Tex. complaint and ITC complaint on the same day (Aug. 19, 2022), and Samsung answered with a wave of five IPRs (IPR2023-00199, -00220, -00221, -00254, -00255) covering all five asserted MRI display-cooling patents. The ITC track ended in MRI's defeat—the ALJ's final initial determination (Nov. 13, 2023) found no violation, the Commission declined review (Feb. 28, 2024), and it denied reconsideration (May 8, 2024). The PTAB track then invalidated all challenged claims of all five patents, and every resulting Federal Circuit appeal affirmed: Nos. 24-2228/-2229 on Mar. 31, 2026; Nos. 24-2224/-2231 here on Apr. 7, 2026; and No. 24-2300 (the '287 patent, IPR2023-00255) by Rule 36 judgment on Apr. 15, 2026—effectively extinguishing MRI's U.S. enforcement position against Samsung's outdoor-display imports (the E.D. Tex. case appears to have gone dormant; its public docket shows little activity after early 2024, and RPX lists it "open" while Ex Parte shows "closed," so its precise disposition is not well sourced from the available records). Beyond the litigation scoreboard, the case matters doctrinally for two reasons: (1) its claim-construction holding reaffirms that ordinary-meaning "heat exchanger" terms will not be narrowed to particular enclosed-channel/tube structures absent clear disclaimer, and (2) its nexus analysis—echoing the March 31, 2026 companion opinion—continues the Federal Circuit's insistence that objective evidence of nonobviousness be tied to the claimed invention, a recurring theme in PTAB appeals involving established operating companies defending older display/cooling patent families.

Framing note: what this case actually is

The docket in the case metadata — Manufacturing Resources International, Inc. v. Squires, Nos. 24-2224, 24-2231 (Fed. Cir.) — is not itself a patent infringement suit. It is a consolidated appeal from two PTAB inter partes review (IPR) final written decisions under 35 U.S.C. § 141/319, in which the USPTO Director (now John A. Squires) intervened to defend the Board after Samsung Electronics entities were terminated as appellees (2024-09-24). The underlying infringement enforcement was a coordinated, dual-track campaign MRI ran in the same timeframe:

• E.D. Tex. — MRI v. Samsung Electronics Co., Ltd. et al., No. 2:22-cv-00320 (Marshall Div., Judge Rodney Gilstrap, referred to Magistrate Judge Roy S. Payne); and
• ITC — Investigation No. 337-TA-1331 (Certain Outdoor and Semi-Outdoor Electronic Displays, Products Containing Same, and Components Thereof).

Both were filed the same day (2022-08-19), and the same five MRI patents were asserted in both: U.S. 8,854,595; 9,173,322; 9,629,287; 10,506,740 (the '740 patent); and 11,013,142 (the '142 patent) — the latter two being the patents covered by this appeal (note: the '142 patent is 11,013,142; the "11013142" in the metadata reflects a dropped leading digit).

The narrative below tracks the infringement campaign and its parallel PTAB proceedings chronologically. Where a district-court fact could not be verified from available public sources, I say so explicitly rather than guess.

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1. Filing and initial pleadings (2022)

• 2022-08-19 — District court complaint. MRI sued Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.; Samsung SDS Co., Ltd.; and Samsung SDS America, Inc. in E.D. Tex. (No. 2:22-cv-00320), alleging infringement of the five patents listed above, with jury demand, AO 120 filings, and claim charts attached (Unified Patents portal docket; UniCourt case summary; RPX Insight: filed 2022-08-19, Judge Gilstrap). Counsel for MRI included Kilpatrick Townsend attorneys (David A. Reed, Russell Korn, Dario Machleidt, Andrea Anderson, Kathleen Geyer, Alton Absher, Steven Borgman).
• 2022-08-19 — Same-day ITC complaint. MRI filed a Section 337 complaint with the U.S. International Trade Commission covering the same accused outdoor/semi-outdoor display products and the same five patents; the Commission instituted Inv. No. 337-TA-1331 (Federal Register notice published 2022-09-23). MRI asserted, among others, claims 1, 5, and 6 of the '740 patent and claims 1–15 of the '142 patent.
• 2022-08-23 to 2022-09-07 — Service and extensions. Summons returned executed on Samsung SDS America (served 2022-08-23); on 2022-09-07 Magistrate Judge Payne granted an unopposed extension to answer/move/respond, and Samsung entities' answer deadline was ultimately set to 2022-12-01 (UniCourt docket entries #14–16). The December extension aligns with Samsung's preparation of IPR petitions and any contemplated threshold motions.
• Answers/counterclaims: I could not verify from available public sources whether Samsung filed substantive answers and counterclaims, or instead filed motions (e.g., to dismiss/transfer/stay) before answering. No answer or counterclaim content is confirmed on the accessible docket record.

2. Samsung's PTAB counteroffensive: five parallel IPRs (Dec. 2022 – 2023)

Samsung's mandatory-relation disclosures and MRI's IPR filings show Samsung petitioned against essentially the entire MRI patent family at issue, including:

• IPR2023-00221 — challenging claims 1–15 of the '142 patent (petition dated 2022-12-07 per Patexia);
• IPR2023-00254 — challenging claims 1–3, 5–9, 11–13, 15–18, and 20 of the '740 patent (Goodwin Procter power of attorney dated 2022-12-06; corrected petition filed 2023-05-09);
• IPR2023-00199, IPR2023-00220, IPR2023-00255 — challenging sibling patents from the same display-cooling family asserted in ITC 1331 (MRI's mandatory notice in IPR2023-00254, filed 2023-02-03, lists all of these as related matters, along with the E.D. Tex. case and ITC 1331).

MRI's Preliminary Response in IPR2023-00254 (2023-03-22) argued the Board should deny institution under § 325(d) (same art already considered during prosecution and in the related Civiq Smartscapes LLC v. MRI, IPR2018-00774, institution denial) and attacked Samsung's failure to address objective indicia of non-obviousness.

Obviousness grounds ultimately at issue (per the expert declarations and Board record):

• '740 patent: obvious over WO 2007/116116 A1 ("Karppanen") and/or GB 2402205 A ("Yare");
• '142 patent: obvious over Karppanen or Yare, each in view of U.S. 6,392,727 ("Larson").

The Board instituted both IPRs in mid-2023 (institution decision in IPR2023-00221 dated 2023-06-20 per Patexia; IPR2023-00254 instituted on a parallel schedule).

Strategic significance: MRI filed the ITC complaint and the E.D. Tex. case on the same day — a classic "dual track" enforcement strategy. Samsung's response was to (a) defend the ITC investigation and (b) file coordinated IPRs on the full asserted patent family, which in turn became the vehicle that ultimately disposed of the infringement claims without a district-court merits decision.

3. Claim construction and the ITC track

• The ITC 1331 investigation included a claim-construction phase in which the parties litigated constructions of numerous terms across the five patents, including "heat exchanger" and "closed loop gas circulation path" (see Samsung's Exhibit 1041 in IPR2023-00221, which reproduces the parties' ITC claim-construction chart).
• According to the PTAB judges at the 2024-03-20 consolidated IPR hearing, the ITC proceeding adjudicated claims 1 and 5 of the '740 patent and claims 6 and 10 of the '142 patent, finding those claims invalid as obvious on the Karppanen-based "Ground 1," while the Commission was "not convinced" of invalidity on the Yare-based "Ground 2." MRI later argued in its IPR sur-reply (2024-01-30) that the ITC initial determination was non-final, based on a different record, and not binding on the PTAB.
• In the IPRs themselves, MRI's expert (Dr. Himanshu Pokharna) defended patentability, and Samsung noticed his deposition for 2023-12-13 (notice filed 2023-11-27). MRI argued for a narrow construction of "heat exchanger" — requiring "alternating, enclosed channels or tubes of fluid" — while Samsung urged the broad plain meaning (a fin/rib can be a heat exchanger).
• The Board rejected MRI's construction, holding that a heat exchanger "may, but does not have to, include enclosed channels or tubes." The Board also found MRI's objective evidence of non-obviousness (commercial success, industry praise, Samsung's praise/collaboration overtures) entitled to "little to no weight" for lack of nexus.

4. PTAB final written decisions and the fate of the district case (2024)

• 2024-03-20 — Consolidated oral hearing in IPR2023-00221 and IPR2023-00254 before APJs Jameson Lee, Jo-Anne M. Kokoski, and John A. Hudalla (transcript filed 2024-05-10). The panel noted this was the first of three requested oral arguments covering five MRI patents asserted in ITC 1331.
• June–July 2024 — The Board issued Final Written Decisions holding all challenged claims of both patents unpatentable as obvious (all claims 1–15 of the '142 patent; claims 1–3, 5–9, 11–13, 15–18, and 20 of the '740 patent). Sources differ on the precise FWD entry date for IPR2023-00221 (Patexia lists the decision date as 2024-06-18; a Google Patents citation references the FWD as July 3, 2024); both fall in the June–July 2024 window.
• Effect on the E.D. Tex. litigation: The district-court docket's last activity per RPX Insight is 2024-03-12, roughly contemporaneous with the ITC/PTAB endgame, and aggregators now mark case 2:22-cv-00320 as closed (Ex Parte) after ~653 days in litigation. I could not verify from accessible sources the specific procedural vehicle that ended the district case — i.e., whether it was stayed pending the IPRs and then dismissed by stipulation/consent, or administratively closed after the PTAB invalidated the asserted claims. No trial, jury verdict, Markman order, summary-judgment order, or fee award in the E.D. Tex. case was located or confirmed; the record is consistent with the case having been parked during the IPR/ITC proceedings and never reaching merits adjudication.

5. Federal Circuit appeals (2024–2026) — the case in the metadata

• 2024-08-16 — MRI appealed the IPR2023-00254 FWD ('740 patent) in No. 24-2224, and the IPR2023-00221 FWD ('142 patent) in No. 24-2231; the appeals were consolidated under 24-2224 (CourtListener docket; CAFC opinion).
• Late 2024–2025 — Samsung Electronics entities, initially appellees, were terminated (2024-09-24); the USPTO Director intervened to defend the Board, with a succession of named Directors/Acting Directors (Katherine Vidal, Derrick Brent, Coke Morgan Stewart, and finally John A. Squires, substituted in the caption on 2025-09-23). Briefing and argument scheduling continued through 2025 (conflict notices filed May–June 2025 and November 2025; argument set for the early-2026 session).
• 2026-03-06 — Oral argument audio posted; argument occurred in the February/March 2026 session before Judges Prost, Taranto, and Stoll. MRI (David Reed, Kilpatrick Townsend) pressed the narrow "heat exchanger" construction based on the inventors' earlier provisional applications and purported disavowal of fin-type exchangers; the PTO Solicitor's Office (Fahd Patel) defended the broad construction and the two-loop invention framing.
• 2026-03-31 — The Federal Circuit issued a related decision, MRI v. Squires, No. 2024-2228, 2026 WL 879712, rejecting materially similar secondary-considerations arguments in a sibling IPR appeal from the same MRI/Samsung patent family — a decision the court later invoked against MRI.
• 2026-04-07 — Opinion (nonprecedential), authored by Judge Stoll, joined by Judges Prost and Taranto: AFFIRMED. The court (1) adopted the Board's construction of "heat exchanger" — plain claim language imposes no enclosed-channel/tube structural requirement; the shared specification says "many types" of heat exchangers are known; and MRI showed no clear lexicography or disavowal under Thorner v. Sony sufficient to import a narrowing limitation; and (2) upheld the Board's decision to give MRI's objective indicia of non-obviousness little weight, rejecting MRI's arguments "for the same reasons" as in MRI v. Squires, No. 2024-2228 (Fed. Cir. Mar. 31, 2026). All challenged claims of the '740 and '142 patents were therefore held obvious (opinion PDF, cafc.uscourts.gov; Fed Circuit Blog summary 2026-04-07; Vital Law/IP Law Daily summary 2026-04-09).
• 2026-04-15 — The related appeal in No. 24-2300 (from IPR2023-00255, another MRI patent in the same family) was affirmed under Fed. Cir. R. 36 (per curiam: Prost, Clevenger, Stark), confirming the family-wide sweep of the invalidation.

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Outcome and bottom line

• The '740 and '142 patents' challenged claims were invalidated as obvious by the PTAB (June–July 2024), and the Federal Circuit affirmed in full on 2026-04-07 (status per the case metadata: "Terminated 2026-04-07; Affirmed").
• The affirmance rests on two holdings: (1) the Board's claim construction of "heat exchanger" (no enclosed channels or tubes required) was correct as a matter of law; and (2) MRI's secondary considerations evidence lacked nexus and was properly given little weight.
• Because the same patents and claims were the basis of MRI's E.D. Tex. infringement action (2:22-cv-00320) and ITC Investigation 337-TA-1331, the PTAB invalidation (now final on appeal) effectively destroyed the infringement theories on those claims. The district case's docket went dormant in early 2024 and is now marked closed — there was no trial, no verdict, and no post-trial motion practice in the district court. The litigation was resolved through the IPR/appeal channel rather than by a merits trial.
• Caveats on sourcing: I could not verify from the public sources available (PACER-derived dockets on UniCourt/Unified Patents/RPX, CAFC opinion PDFs, PTAB filings via DocketAlarm/Patexia, the Federal Register, and legal press) the specific contents of Samsung's answer/counterclaims, any motions to dismiss/transfer/stay and their rulings, any district-court Markman order, or the exact final dismissal instrument in 2:22-cv-00320. Those events likely occurred but are not confirmed here; the confirmed, dispositive events are the PTAB Final Written Decisions and the Federal Circuit's 2026-04-07 affirmance.

Note on framing: This case is not a patent infringement suit. It is a Federal Circuit appeal by patent owner Manufacturing Resources International, Inc. ("MRI") from PTAB final written decisions in IPR2023-00254 ('740 patent) and IPR2023-00221 ('142 patent), consolidated as 24-2224 (lead) / 24-2231. Samsung (the IPR petitioner) was initially named appellee but was terminated in September 2024; the USPTO Director intervened as appellee. MRI is therefore the appellant/patent owner, and the "plaintiff" designation in the user's question maps to MRI.

Counsel of record for MRI (appellant) in 24-2224/24-2231

All four counsel entered appearances for MRI on August 29, 2024 (24-2224 entry of appearance docketed as entry 2; 24-2231 entry 2), per PACER/CourtListener and Justia docket records. The Federal Circuit's nonprecedential opinion (issued April 7, 2026) identifies David A. Reed as arguing counsel, with Morlock, Alemanni, and Sanders also of record.

Grounding and caveats

• Docket entries: Justia's docket for 24-2231 (entry 2, filed 8/29/2024): "Entry of Appearance for John C. Alemanni; Michael T. Morlock; David A. Reed; Carl E. Sanders as counsel for Appellant Manufacturing Resources International, Inc." (PACER entry 1028983/1028970 for the lead case).
• Opinion: Vitallaw summary of the Federal Circuit decision confirms: "David A. Reed, Kilpatrick Townsend & Stockton LLP, Atlanta, GA, argued for appellant. Also represented by Michael T. Morlock; John C. Alemanni, Carl Sanders, Raleigh, NC."
• CourtListener docket 72065036 party listing confirms Sanders (Raleigh), Reed (Atlanta), Alemanni, and Morlock as MRI's retained counsel of record.
• I could not confirm from the retrieved sources whether Michael T. Morlock's office is Atlanta vs. another Kilpatrick Townsend location; his entry of appearance address wasn't captured in the search results. If you need it, check PACER entry 2 in 24-2224 directly.
• No in-house counsel, local counsel (Federal Circuit practice doesn't use that designation), or pro hac vice designations appear in the docket. The USPTO Director's office (Office of the Solicitor – Fahd H. Patel, Michael S. Forman, Peter J. Ayers) represents the appellee/intervenor, not MRI.

Threshold clarification: this is not a patent infringement case

Before identifying counsel, an important framing point from the docket and the Federal Circuit's opinion:

• 24-2224 (lead; consolidated with 24-2231) is MRI's appeal of PTAB final written decisions in IPR2023-00254 ('740 patent) and IPR2023-00221 ('142 patent) — an administrative patent appeal, not a district-court infringement action. Manufacturing Resources Int'l, Inc. v. Squires, Nos. 24-2224, 24-2231 (Fed. Cir. Apr. 7, 2026) (nonprecedential), slip op. at 1–2.
• The nominal appellee at docketing was Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (the IPR petitioners), but Samsung filed a Notice of Non-Participation and was terminated from the appeal on Sept. 24, 2024 (CourtListener docket, Dkt. 24-2224; entry filed 09/03/2024 by Sanjeet Dutta; caption order of 09/24/2024).
• After Samsung's exit, the court ordered the PTO to state whether it would intervene; the Director of the USPTO intervened under 35 U.S.C. § 143 (notice of intervention filed 10/24/2024) and is the party actually defending the Board's decision on the merits. Successive Directors were substituted into the caption (Katherine K. Vidal, terminated 12/17/2024; Derrick Brent, terminated 1/23/2025; Coke Morgan Stewart, terminated 9/23/2025; John A. Squires, substituted 9/23/2025).

So the "defendant-side" representation on the merits is the U.S. Patent and Trademark Office – Office of the Solicitor in Alexandria, VA, representing the Director/Intervenor.

Counsel of record for the Director of the USPTO (the defending party on appeal)

All counsel below are government attorneys at the Office of the Solicitor, United States Patent and Trademark Office, P.O. Box 1450, Mail Stop 8, Alexandria, VA 22313 (per the CourtListener/PACER-derived docket and the opinion's counsel line).

Role designations caveat: PACER/Federal Circuit dockets do not use formal "lead/of counsel/local counsel" labels in the way district-court complaints do; the opinion itself distinguishes only "argued for intervenor" (Patel) versus "also represented by" (Matich, McManus, Tyler). Forman and Ayers appear as counsel of record on the docket's party page for Squires. I could not independently verify each solicitor's internal title (e.g., Deputy Solicitor vs. Associate Solicitor) from the sources retrieved, so I have not assigned titles beyond "USPTO Office of the Solicitor."

Samsung (original appellee — no longer of record)

Samsung filed a Notice of Non-Participation (docket entry dated 09/03/2024, submitted by Sanjeet Dutta) and was terminated from the case on Sept. 24, 2024. Samsung therefore has no counsel of record currently defending anything in this appeal; the docket does not identify Dutta's firm in the snippets available, and I would not speculate as to his firm without PACER confirmation.

Bottom line

If "defendant(s)" means the party resisting MRI on appeal, the counsel of record are the USPTO Office of the Solicitor attorneys above, led at argument by Fahd H. Patel, with the balance of the solicitor team (Matich, McManus, Tyler, Forman, Ayers) as counsel of record. Samsung's private counsel are not of record, having withdrawn via non-participation in September 2024. No filings are sealed that would hide additional counsel, based on the public docket entries reviewed.

Sources: CourtListener docket 24-2224 (entries 1, 7, 43–48; parties page); Federal Circuit opinion in 24-2224/24-2231 (Apr. 7, 2026), available at cafc.uscourts.gov and CourtListener; companion Rule 36 order in 24-2300 (Apr. 15, 2026), available at cafc.uscourts.gov.